Where delay between offence and sentence is caused by the offender's own conduct (absconding, ignoring proceedings), any rehabilitation achieved during that period is properly discounted as a mitigating factor. The offender cannot claim the full benefit of rehabilitation where the freedom enabling it flowed from the offender's avoidance of sentence. Section 13A(7)(b)(i) of the PSA does not require precise statutory language; any formulation making clear the sentence is reduced under s 13A suffices.
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