In exceptional cases a non-custodial sentence was appropriate for an offence of rape of a child under 13 years old. Digital penetration of the anus of a child under 13 years old, contrary to the Sexual Offences Act 2003 s.6, was a very serious offence that could justify a life sentence. Preliminary non-prescriptive guidance given as to the approach to sentencing in relation to offences under the Sexual Offences Act 2003.

[2005] EWCA Crim 192

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