In sentencing for extra-territorial child sex offences, the absence of a breach of trust as commonly understood in a domestic setting is unremarkable and should not be treated as a significant mitigating factor, given the inherent vulnerability and accessibility of overseas child victims. A child victim's perception that the relationship was beneficial does not diminish the gravity of the offending. The Ellis discount, while significant where admissions were essential to prosecution, does not render otherwise appropriate sentences manifestly excessive where the offending involved sustained exploitation of a vulnerable child over an extended period.
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