Sentences for s 66A(2) offences must reflect the 2009 increase in maximum penalty from 25 years to life imprisonment. Grooming of a child victim through display of pornographic material is a significant aggravating factor demonstrating planning and organisation, and exacerbates the offending by introducing a further corrupting influence. The interrelationship between possession of child abuse material and direct sexual offending against children is a relevant sentencing consideration. An aggregate sentence of 8 years for multiple s 66A(2) offences involving grooming, exploitation of trust, and a course of conduct over months was manifestly inadequate; the appropriate aggregate sentence was 14 years (NPP 9 years 6 months).
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