A non-custodial sentence (good behaviour bond) for an accessory before the fact to armed robbery is not necessarily manifestly inadequate where the offender's subjective circumstances are exceptionally favourable, including youth, first offence, genuine remorse, excellent rehabilitation prospects, and being overborne by the co-offender. The characterisation of the offender's assistance as 'substantial' does not preclude a non-custodial sentence in such circumstances. The Court left open whether a full discount for a plea of guilty should be available where the plea is entered only after the Crown indicates willingness to accept a plea to a lesser charge and the saving to the community is minimal.
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