Where multiple sexual offences are committed as part of a single episode, s 6E of the Sentencing Act 1991 must be given its proper effect, but a sentencing judge should not put entirely to one side the one episode principle or set at nought the requirements of totality. The certainty of deportation following visa cancellation, as distinct from the mere likelihood of deportation, constitutes new evidence that vitiates the sentencing discretion and warrants resentencing on appeal. The Parole Board's changed practice of being less inclined to grant parole to prisoners facing deportation is a relevant consideration in assessing the burdensomeness of imprisonment for foreign nationals.
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