For historical child sexual offences involving digital penetration by a parent against a child under 14, a head sentence of four years' imprisonment with two years to serve is within range where there is a complete absence of remorse and a serious breach of parental trust. The passage of time between offending and sentencing does not of itself require a lower sentence where the offender has not demonstrated rehabilitation or acknowledged wrongdoing — the principles in R v Illin regarding delay between charge and sentence are distinct from mere historical delay.
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