When an offender is sentenced on a later occasion for sexual offending against children that occurred before the commencement of an earlier sentence for related offending, the totality principle requires primary regard to be had to the sentences imposed on both occasions and the offending as a whole. The mitigating effect of guilty pleas must be reflected not only in individual sentences but in the total effective sentence, particularly in child sexual abuse cases where the trial process risks re-traumatising victims.
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