A sentencing judge's failure to allow a discount for the utilitarian value of a guilty plea to a Commonwealth offence, where the sentence was passed before Xiao v R [2018] NSWCCA 4 and Jinde Huang v R [2018] NSWCCA 70, constitutes an error warranting resentencing. The degree of difference necessary to maintain an appropriate relationship between co-offenders' sentences is a matter of broad discretionary judgment, not precise mathematical calculation.
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