The absence of aggravating factors (such as threats, multiple aggravating features, or ejaculation) does not diminish the gravity of a sexual offence. There is no hierarchy of sexual offences ranked by the type of penetration or sexual connection; forced fellatio is not inherently less serious than vaginal or anal penetration. The assessment of objective seriousness of an offence is quintessentially for the sentencing judge and is reviewable only on [name withheld] principles.
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