Aae v WA

[2024] WASCA 35

Western Australia Court of Appeal

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Interrogate

Catchwords

1. Criminal Law
2. › Appeal
3. › Appeal against sentence
4. › Child sexual offences
5. › Sexual penetration and indecent dealing offences
6. › Indecent recording
7. › Possession and distribution of child exploitation material
8. › 52 offences over 11 months
9. › Whether total effective sentence of 17 years 6 months breached totality principle
10. › Criminal Code (WA), ss 219, 220, 320(6), 329
11. › Sentencing Act 1995 (WA), s 9AA

Quick Take

A small number of comparable cases cannot be used to establish a tariff or ceiling for child sexual offending sentences; the totality principle requires a holistic assessment of overall criminality.