A sentencing judge is not obliged to treat onerous bail conditions as the notional equivalent of custody warranting credit in sentence, though it is open to do so. The discount for utilitarian value of a guilty plea reflects the practical benefit of the plea and does not invite investigation into why the accused delayed pleading. Extra-curial punishment in the form of injuries sustained during arrest by police is a relevant mitigating factor following R v Daetz, though the correctness of that decision was left open.
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