Where an offender commits child sex offences against multiple separate victims, the aggregate sentence must include meaningful accumulation to ensure punishment referable to each victim. Kidnapping offences that involve additional criminality beyond the detention necessary to commit the sexual offence require some level of accumulation with the sexual assault counts. Offending while on conditional liberty for similar offences is an important aggravating feature that must be taken into account. When sentencing historical offences where sentencing statistics are unavailable, the maximum penalty and range of criminality encompassed by the offence are the most useful objective guides.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.
1 of the 2 citing cases carry a classified treatment. How each court treated it is available to signed-in members.