A total effective sentence of 6 years 6 months' imprisonment for 9 counts of child sexual offending (including multiple penile penetration offences) against a 7-8 year old stepdaughter, committed by an offender with prior child sex convictions, was held to infringe the first limb of the totality principle. The Court resentenced to 9 years' imprisonment, emphasising the need for greater accumulation to reflect the overall criminality.
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