In R. v. B.M. (Ont CA, 2023) the Court of Appeal characterizes child sex assault:
 It is a well-established principle of this court that “[s]exual abuse is an act of violence. When committed against children, the violence is both physical and profoundly psychological. It is coercive and exploitative conduct, and represents the use of compulsion against someone who is defenceless”: R. v. Stuckless (1998), 1998 CanLII 7143 (ON CA), 41 O.R. (3d) 103 (C.A.), at p. 117, per Abella J.A. (as she then was).
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