When applying the Nagy approach to totality for multiple federal child sexual exploitation offences, a modest uplift to the most serious count will not suffice where additional counts involve different victims and qualitatively different offending; the Pearce approach of partial cumulation may be more appropriate. A non-parole period of approximately 38% of the head sentence is likely to be disproportionately low for serious child sex tourism offences, even with mitigating factors. Sentencing patterns for offences under s 272.11(1) of the Criminal Code (Cth) remain undeveloped, but the absence of comparable cases does not prevent a finding of manifest inadequacy.
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