Where a sentencing judge's remarks on sentence do not refer to the utilitarian value of guilty pleas, and the pleas were not mentioned during oral submissions, and there is no indication from the specification or manner of calculation of the sentences whether any discount was applied, it is not possible to infer that the pleas were addressed as required by s 22(1) of the Crimes (Sentencing Procedure) Act 1999 (NSW). This constitutes material error warranting resentencing.
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