A plea of guilty alone does not constitute 'cooperation with law enforcement agencies' within the meaning of s 16A(2)(h) and s 21E of the Crimes Act 1914 (Cth), and sentencing judges should use terminology that clearly distinguishes between the two. Even where a sentencing judge's use of the term 'cooperation' is ambiguous, a Crown appeal will not succeed where the sentence, though lenient, can be justified by other mitigating factors and the proper administration of justice does not plainly require the sentence to be increased.
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