Uncharged criminal conduct may be used on sentence for three permissible purposes without breaching the De Simoni principle: (1) to show the charged offence was not an isolated incident; (2) to assess the veracity and reliability of the offender's account; and (3) to inform the seriousness of the charged offence. A co-offender's guilty plea discount must be taken into account when comparing sentences for parity purposes, such that the notional pre-discount starting point is the relevant comparator.
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