In sentencing for voyeuristic filming offences under ss 91G, 91K and 91L of the Crimes Act 1900 (NSW), the absence of physical contact, the fact that victims were unaware of the filming, and the fact that material was not disseminated do not mitigate the objective seriousness of the offending. An aggregate sentence of 6 years (NPP 3½ years) for 10 counts with 14 Form 1 offences involving 8 teenage victims over 7 years, with significant breach of trust and deliberate modification of premises, was within range.
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