The utilitarian value of a guilty plea must always receive a discount in sentencing, and that discount is not to be reduced on a sliding scale according to the objective gravity of the offence. The only exception remains the rare case where the gravity is such that no discount from the maximum sentence is appropriate. The totality principle and the concept of a 'crushing' sentence are discrete concepts requiring separate consideration. As the objective gravity of total offending increases for serious sexual offenders under s 6E, the degree of cumulation ordered will increase, but the precise relationship between s 6E and the totality principle remains unresolved.
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