The general principles in R v Thomson and Houlton regarding utilitarian discounts for guilty pleas apply to Commonwealth offences, and the range of 10-25% discount is a reasonable range to adopt for Commonwealth matters. The predominant consideration for the quantum of utilitarian discount is the timing of the plea, not the strength of the Crown case. A repeat offender who pleads guilty at the earliest opportunity is entitled to a significant utilitarian discount notwithstanding the seriousness of the offence or prior record.
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