The standard non-parole period under s 54B of the Crimes (Sentencing Procedure) Act 1999 applies as a reference point in cases resolved by guilty plea, not only in cases determined after trial. The passage in R v Mouloudi stating that the discretion after a plea is 'unfettered' does not mean s 54B is to be ignored. The strength of the Crown case remains irrelevant to the utilitarian value of a guilty plea discount, though an identified sentencing error does not require appellate intervention unless a more lenient sentence is warranted.
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