Evidence in support of course of conduct charges under cl 4A of sch 1 of the Criminal Procedure Act 2009 (Vic) need not be 'capable of distillation into incidents or occasions'; evidence that offending occurred 'numerous times' or 'fairly often' over a specified period is sufficient, even where the complainant cannot recall specific incidents. A total effective sentence of 21 years' imprisonment for multiple charges of incest and indecent acts with children under 16, committed against four stepchildren over approximately a decade, was upheld by the majority as not manifestly excessive, though Priest JA would have reduced it to 17 years.
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