The utilitarian discount for an early guilty plea must be calculated without reference to the strength of the Crown case, and a discount of at least 25 per cent is generally available for pleas at the first opportunity. Where fraud offences involve separate victims and distinct criminal conduct, concurrent sentences will generally be inappropriate and some measure of accumulation is required. For offences of perverting the course of justice under s 319, the fact that the attempt did not succeed is of far less significance than in sentencing for an attempt to commit a substantive crime; the nature and degree of the intended perversion is the major factor.
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