The Minehan list of factors relevant to objective seriousness of child abuse material offences has been updated to include (1) the degree of deception employed by the offender in acquiring material, and (2) the age of any person with whom the offender communicated relative to the offender's age. Sentencing judges are not required to view samples of child abuse material in every case; adequate written descriptions will generally suffice. A sentence characterised as 'very lenient' is not necessarily manifestly inadequate, and a Crown appeal may be dismissed in the exercise of discretion where the Crown advances a case on appeal not articulated below.
The full text is available to signed-in members, including the 61 later cases that cite this judgment.
22 of the 61 citing cases carry a classified treatment. How each court treated it is available to signed-in members.