Time spent in strict residential drug rehabilitation programs as a condition of bail constitutes quasi-custody for which sentencing credit should be given. An offender's motivation for entering the program (including a desire to create a favourable impression at sentencing) and failure to complete the program are relevant to assessing rehabilitation prospects but do not disentitle the offender from quasi-custody credit. The case distinguishes R v Kivits, where no credit was given because the program was a 'boon' to a destitute offender.
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