When sentencing for historic sexual offences, the 25% discount for an early guilty plea must be applied to indicative sentences as a procedural rule applicable at the time of sentencing, not the time of offending. A familial relationship as uncle or cousin does not without more constitute a 'position of trust' under s 21A(2)(k) where the offender was not left in charge of the children. Findings as to risk of re-offending require evidentiary support and cannot be based on judicial speculation about the consequences of not having undergone counselling, particularly where the offender has not re-offended for approximately 40 years.
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