The Ellis discount for voluntary disclosure of otherwise unknown criminality is a factor in the sentencing process, not a rule to be applied as a separate quantified mathematical discount alongside discounts for plea and assistance. An overall discount of more than 60%, however derived, will rarely if ever result in a sentence that is not manifestly inadequate. A question of parity always arises where co-offenders are sentenced for the same offence, and a sentencing judge cannot completely disregard the sentences imposed on a co-offender. Where disparity with a co-offender's manifestly inadequate sentence is so gross and unreasonable, the Court of Criminal Appeal may intervene even though the co-offender's sentence is too inadequate to serve as a benchmark.
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