The case confirms that a sentence for multiple child sexual assault offences over a 20-year period involving 7 victims may be regarded as lenient without being manifestly inadequate for Crown appeal purposes. The seriousness of fantasy material in child abuse material offences is to be assessed on a case-by-case basis rather than treated as equally serious to material depicting actual children. An erroneous approach to indicative sentences may reveal error in an aggregate sentence, but the indicative sentences themselves are not appellable.
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