A sentencing judge may not arrive at a sentence and then add or subtract a period to reflect a particular factor such as a forfeiture order; the forfeiture must be taken into account as part of the intuitive synthesis. The manifest excess ground can only be directed at the sentence actually imposed, not at a hypothetical starting point. The greater the number of individual victims of sexual offences, the greater the overall gravity of the offending, but this does not aggravate any individual offence. The appendix provides a useful survey of sentencing practices for s 47 indecent act offences.
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