Sentencing judges must not assume that protective custody will be more onerous than general population without evidence being placed before the court; if the offender wants this taken into account, the offender must present evidence. The utilitarian value of a guilty plea does not include sparing witnesses from giving evidence. Where no sentencing range for historical offences can be established, the court should sentence by reference to the nature of the criminal conduct and the maximum penalty applicable at the time of offending. Separate child pornography offences committed with different persons at different times should not be made wholly concurrent.
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