Where an offender is not charged with the aggravated form of a sexual offence against a child (under care, supervision or authority), the sentencing judge may still treat breach of trust as a significant aggravating feature without offending the De Simoni principle. A rolled-up charge encompassing two forms of penetration in a single episode justifies a higher individual sentence than would a single act of penetration. Comparable sentences are not precedents and do not cap or collar the sentence appropriate in a given case.
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