A 15% discount for the utilitarian value of guilty pleas is appropriate where pleas are entered after a trial date has been fixed, even where the Crown has contributed to delay in determining charges, because the offender knew what offences he had committed and could have indicated willingness to plead earlier. R v Todd delay principles do not automatically result in mitigation; the offender's own contribution to delay and absence of evidence of deterioration caused by delay may negate any entitlement to mitigation on this ground. The Court signalled that the sentences imposed for these vehicle re-birthing offences were lenient and should not be used as benchmarks.
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