The relevant date for determining whether changed sentencing practice (such as that directed in Harrison & Rigogiannis) applies is the date of arraignment (formal plea of guilty), not the date a plea is indicated at committal mention. However, the fact that a guilty plea was indicated before the change in sentencing practice remains a relevant consideration in sentencing. Increases in sentencing practice following appellate guidance should ordinarily be incremental.
The full text is available to signed-in members, including the 8 later cases that cite this judgment.
1 of the 8 citing cases carry a classified treatment. How each court treated it is available to signed-in members.