The forced administration of drugs to a victim for the purpose of ensuring compliance with sexual acts is a significantly aggravating feature that elevates the objective seriousness of sexual offending. Caution should be exercised in comparative sentencing analysis as all cases are different and particular features may be unusual or unique to the offending. Uncharged conduct forming part of the context of a charged offence may be referred to in sentencing remarks without constituting sentencing for uncharged acts, provided it is established beyond reasonable doubt.
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