Following Xiao v R, sentencing judges for Commonwealth offences must take into account both the utilitarian value and the subjective value of guilty pleas under s 16A(2)(g) of the Crimes Act 1914 (Cth). However, an increase in the discount for the plea (here from 15% to 20%) does not necessarily result in a lesser overall sentence where the objective seriousness of the offending and the need for deterrence dictate otherwise. The NSW guideline judgment in R v Thomson; R v Houlton does not apply to Commonwealth offences.
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