Co-operation by an accused in the conduct of a trial may be taken into account in mitigation of sentence even absent remorse, but only where the co-operation has genuine utilitarian value — no reduction is warranted where no rational person would have prolonged the trial by putting in issue matters the Crown was plainly in a position to prove. The adequacy of jury directions on the elements of a drug offence must be assessed in the context of the issues actually joined at trial, not in the abstract.
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