Post-sentence evidence of actual conditions of custody is admissible on a sentence appeal where it demonstrates that the basis upon which the sentencing discretion was exercised has been undermined because the conditions were materially different from those contemplated by the sentencing judge. The exception is strictly circumscribed and applies only in rare and exceptional cases. The Court confirmed that systematic social security fraud ordinarily calls for custodial sentences, even for elderly and seriously ill offenders, but the custodial period may be adjusted where the actual conditions of imprisonment are materially more onerous than those envisaged.
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