Following Cameron v The Queen [2002] HCA 6, the utilitarian value of a guilty plea must be assessed from the perspective of the offender's willingness to assist the administration of justice, though s 22(1)(b) of the Crimes (Sentencing Procedure) Act 1999 (NSW) may distinguish the NSW position. A finding of special circumstances based on rehabilitative prospects is not appropriate where the offender has demonstrated a persistently defiant attitude to the law and the psychologist's report indicates poor prospects of rehabilitation. For aggravated dangerous driving occasioning death involving a prolonged high-speed police chase through suburban streets resulting in death, a sentence of seven years with a four-year non-parole period was manifestly inadequate; eight years with a six-year non-parole period was the minimum appropriate sentence.
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