In sentencing for child exploitation material offences, the quality of the material (the degree of cruelty, degradation and corruption depicted) is more determinative of gravity than the quantity. A sentencing judge is not bound by the range advocated by counsel and has a duty to impose the correct sentence, including actual custody where warranted, notwithstanding a prosecution submission that no actual custody is required. The difference between still images and video is of no great moment in assessing culpability.
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