R v Grehan does not set the top of the permissible sentencing range for child exploitation material offences and is distinguishable where the offending period is longer, the offender's mental disorder does not explain the level of offending, and the maximum penalty has increased. A sentencing judge who accepts that an offender's medical conditions make incarceration specifically onerous does not err by requiring actual custody where the sentence is significantly moderated to account for those conditions.
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