Admissions by an accused that constitute the sole evidence of an offence, made in circumstances where the likelihood of police uncovering the evidence independently was slight, attract an added element of leniency under Ellis principles beyond the utilitarian value of a guilty plea. However, admissions regarding offences where the accused was already found in possession of the relevant drugs do not constitute disclosure of otherwise unknown guilt. Form 1 offences should generally be attached to the more serious offence to allow maximum sentencing flexibility. A sentencing judge is not required to quantify the discount for a plea of guilty on each count separately.
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