Following Xiao v R, sentencing judges must take into account the utilitarian value of a guilty plea in addition to subjective factors such as contrition or remorse. However, where the plea is entered at a late stage, the utilitarian discount may be limited to 10 per cent. For importation of approximately 17 kilograms of pure methamphetamine by a person playing a central role at the Australian end, a sentence of 12 years with a 7-year non-parole period is within the appropriate range.
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