A total effective sentence of 18 years and 8 months for incest and associated offences involving a single victim aged 13-17 over four and a half years, with degrading conduct and child pornography, was outside the range reasonably open when measured against current sentencing practices. The case provides a detailed survey of comparable sentences for incest in Victoria, establishing that even very serious cases falling short of the worst category (involving younger children, multiple victims, overt violence, or longer duration) should attract sentences consistent with the established range. A discount for a guilty plea must always be allowed and must find real, discernible and palpable recognition in the sentence.
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