A sentencing judge is not required in every case of voluntary disclosure of guilt to allow a 'considerable' or 'significant' discount or to expressly quantify the discount in remarks on sentence. The Ellis statement that voluntary disclosure merits a 'significant added element of leniency' is a general principle or factor, not a rigid rule. Prior NSWCCA decisions following Kirby J's minority view in Ryan v The Queen requiring a considerable or significant discount should not be followed.
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