The degree of leniency to be afforded for delay between offending and sentencing depends on the reason for the delay; where the delay is largely attributable to the offender's own conduct in contesting charges, the offender is not entitled to the high degree of leniency contemplated by R v Todd. Rehabilitation during the period of delay remains a relevant sentencing factor regardless of the cause of delay, but the sentencing judge retains a broad discretion as to the weight to be given to it.
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