Where subsequent offending is admitted by an offender at a plea hearing, a sentencing judge may use it not only to assess rehabilitation prospects but also to negate or qualify mitigating inferences as to remorse and to inform the weight given to specific deterrence. The use of subsequent charges is more attenuated than subsequent convictions, and where charges are contested, the fact of the charges themselves will usually be irrelevant. Neither Trikilis v The Queen nor Ceylan v The Queen confines the relevance of subsequent charges solely to rehabilitation.
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