Significant psychological harm to a victim may be inferred from the objective circumstances of the offending without expert or medical evidence, even where the evidentiary status of victim impact statements is uncertain. The aggravating factor of planned criminal activity under s 21A(2)(n) of the CSPA may be established notwithstanding that some degree of preconcert is inherent in offences committed 'in company', where the planning goes beyond the minimum required for the offence.
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