A dispute about the characterisation of one offence does not justify delay in entering guilty pleas to other offences and does not constitute 'exceptional' circumstances warranting the full 25% discount. The assessment of objective gravity in child pornography cases focuses on the material that is the subject of the charges, not its proportion relative to lawful material. The restraint inherent in Crown appeal dispositions means those cases should not be regarded as reliable indicators of appropriate sentences at first instance.
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