Individual sentences of four years' imprisonment for incest involving penetrative sexual intercourse with a step-daughter aged 11-14 are manifestly inadequate; six years per charge was appropriate in circumstances involving breach of trust, aggravating post-offence conduct, and a criminal history of violence against women. The totality principle must be modified to give proper effect to the serious sexual offender cumulation provisions in ss 6E and 16(1A) of the Sentencing Act 1991.
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