Criminal law – Child sex offences. The Court of Appeal, Criminal Division, refused an application by the Attorney General to refer a sentence as being unduly lenient pursuant to s 36 of the Criminal Justice Act 1988. The offender had been convicted of the rape of a child under 13 contrary to s 5(1) of the Sexual Offences Act 2003 and sentenced to seven years' imprisonment. The rape had occurred when the offender's seven year old daughter had got into the offender's bed in the night and the offender claimed to remember nothing of the incident. The court noted the unusual circumstances of the case and held, amongst other things, that the judge had not downplayed, or not unreasonably downplayed, the relationship of father and child.