Credit for time on bail is not limited to cases of rehabilitation custody but may extend to onerous bail conditions that restrict liberty, and the determination of the appropriate allowance is a discretionary judgment reviewable only for House v The King error. The residual discretion on a Crown appeal may be exercised where the sentencing judge had the advantage of observing the offender and formed a clear view about the risk of returning the offender to custody, even where the non-parole period verges on manifest inadequacy.
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