The principles in R v Borkowski concerning the assessment of the utilitarian value of guilty pleas for State offences provide practical guidance for Commonwealth offences under s 16A(2)(g) Crimes Act 1914 (Cth). The utilitarian value of a plea is an objective factor to be preferably quantified, determined primarily by timing, and is distinct from the subjective factor of willingness to facilitate the course of justice under s 16A(2)(f), although these factors may overlap. Reasons for delay in entering a plea do not affect the utilitarian value assessment but may bear on the subjective facilitation factor.
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