A total effective sentence of 10 years and 9 months' imprisonment with a non-parole period of 8 years for mid-range incest offending involving oral penetration of a step-child aged 11-12, accompanied by other sexual offences, is within the range reasonably open to a sentencing judge. The 'changing landscape for incest sentencing' continues to support sentences at the higher end of the range for mid-range offending. The fact that a comparator case involving objectively more grave offending resulted in a slightly lesser sentence does not establish manifest excess, as each case must be assessed on its own facts.
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