Failure to take into account the utilitarian value of a guilty plea when sentencing for Commonwealth offences constitutes House v R error requiring resentencing. An unexplained difference in the ratio of non-parole period to head sentence between co-offenders sentenced separately, without subjective features justifying the difference, gives rise to a justifiable sense of grievance. The De La Rosa principles regarding mental illness do not provide an automatic basis for sentence reduction; a causal connection between the mental illness and the offending must be demonstrated for moral culpability to be reduced.
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