Sentencing judges must take into account the utilitarian value of a plea of guilty for Commonwealth offences, and failure to do so constitutes error (applying Xiao v R and Jinde Huang). Where pleas of guilty to State and Commonwealth offences are entered at the same time and for the same utilitarian reasons, the same discount should rationally apply to both. A sentencing judge who states an intention to partially accumulate sentences but in fact imposes total accumulation commits an error in the application of the totality principle.
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