Where abuse of trust and abuse of authority under s 21A(2)(k) arise from the same facts (here, the familial relationship of grandfather to granddaughters), a sentencing judge must not give added weight to abuse of trust in relation to offences where being under authority is already an element. Where offences specifically relate to children within a particular age range, the vulnerability aggravating factor in s 21A(2)(l) is not relevant. A bare reference to having considered s 21A factors is inadequate where specific aggravating factors have been the subject of submissions and there is a risk of double counting; what is required is a succinct statement of the approach adopted on sentence concerning the particular s 21A factors addressed in submissions.
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