The Ellis/Latina principle entitling an offender to a separate and substantial degree of leniency for admissions applies not only where admissions establish an otherwise unprovable offence, but also where they enable the prosecution to establish that the offence was more serious than could otherwise have been ascertained. General sentencing principles from Nguyen v The Queen [2016] VSCA 198 concerning commercial quantity cultivation (including the primacy of general deterrence and cumulation for theft of electricity) may be applied with appropriate adaptation to cultivation simpliciter. A sentencing judge's use of the words 'valuable' and 'voluntary' in describing admissions, in a passage separate from discussion of the utilitarian value of the guilty plea, may be sufficient to demonstrate that the admissions were treated as an independent mitigating factor.
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