Voluntary self-referral to residential rehabilitation programs can constitute quasi-custody warranting a backdating of sentence; legal compulsion (such as a Griffiths remand or bail condition) is not a precondition. The determinative question is whether the offender in fact subjected himself to the restrictions of the program. The standard credit rate of approximately 50% of time spent in quasi-custody, applied by backdating the sentence commencement date, was confirmed.
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