When sentencing for multiple offences, the sentencing judge must differentiate between the objective seriousness of each offence in accordance with Pearce v The Queen; identical concurrent sentences without differentiation will often indicate error. The utilitarian value of an early guilty plea must be separately recognised and given effect to, distinct from the plea's evidentiary value as to contrition; limiting the reference to the plea to contrition alone, without addressing utilitarian value, constitutes error. Where the Crown case is very strong and straightforward, the discount for the utilitarian value of the plea should be at the lower end of the range.
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