A bare finding of 'no special circumstances' without reasoning is insufficient where the evidence discloses matters capable of constituting special circumstances, particularly rehabilitation prospects. The R v Ellis discount for voluntary disclosure of guilt does not apply where the offender's surrender was triggered by the discovery of the offence and arrest of co-offenders, and the offender's identity was potentially discoverable from the parcel itself. R v Thomson and Houlten does not require a sentencing judge to state a precise percentage discount for a plea of guilty.
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