The Skedgwell guidance that a sentencing judge should make plain whether and to what extent allowance is made for non-declarable pre-sentence custody is an important practice direction but not a legal requirement, non-compliance with which necessarily involves sentencing error. A sentencing judge is not obliged to announce two sentences (one with and one without the non-declarable period) to demonstrate the allowance made. The indicative sentencing range for a mature offender who pleads guilty to large-scale trafficking in a schedule 1 drug is 10 to 12 years.
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