A sentencing judge is not constrained by a plea of guilty to a course of conduct charge to find only the minimum two incidents; the judge must determine the course of conduct in which the offender engaged and sentence to reflect the totality of the offending. The High Court decisions in [name withheld] and [name withheld] concerning the South Australian offence of persistent sexual exploitation of a child have no bearing on Victorian course of conduct charges under cl 4A of sch 1 to the Criminal Procedure Act 2009. A voluntary disclosure of offending that is in substance an attempt to minimise the scope of known offending attracts at most a modest sentencing discount.
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