The utilitarian discount for a guilty plea must not be reduced on the ground that the plea was offered in association with the Crown's abandonment of a more serious charge, and such a plea should be treated as made at the earliest opportunity. However, where a plea is entered long after first being charged but at the time a lesser charge is substituted, the reduced advantages to the administration of justice may justify a smaller discount. The strength of the Crown case is irrelevant to the utilitarian discount, though it may be relevant to whether the plea indicates remorse. A minor error in quantifying the discount does not necessarily enliven the appellate power to re-sentence if the overall sentence is appropriate.
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