Offences of rape committed on successive days at different locations, connected by a course of kidnapping conduct over approximately 40 hours, are not properly viewed as part of a single episode for the purposes of the one-transaction rule. Some cumulation is expected in cases of multiple sexual offending even where the offences involve the same victim and are closely associated in time. The presumption of cumulation under s 6E of the Sentencing Act 1991 (Vic) for serious sexual offenders supports orders for cumulation on sexual offence charges.
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