No Entitlement to a One‑Third Sentence Reduction for Signed Pleas and the Limited Reviewability of DPP Consent Decisions: A Commentary on Greaney v DPP & Ors [2025] IEHC 731

1. Introduction

This judgment of Mr Justice Cian Ferriter in Conor Greaney v The Director of Public Prosecutions & Ors ([2025] IEHC 731, 18 December 2025) clarifies several important points of Irish criminal and constitutional law:

The scope of the Director of Public Prosecutions’ (DPP) statutory discretion to refuse consent to an accused being sent forward for sentence on a signed plea of guilty under s.13 of the Criminal Procedure Act 1967.
The nature of sentencing discounts for guilty pleas under s.29 of the Criminal Justice Act 1999, and in particular whether a signed plea gives rise to a right to a one‑third reduction.
The limited circumstances in which prosecutorial decisions are amenable to judicial review.
When constitutional challenges to sentencing-related provisions are premature, by applying the Supreme Court’s decision in Galvin v DPP [2025] IESC 35.

The case sits at the intersection of prosecutorial discretion, sentencing practice, and fair trial rights. The applicant argued that the DPP’s refusal to consent to a signed plea effectively deprived him of a substantial sentencing benefit and so was unfair and unconstitutional. The High Court rejected that proposition and reaffirmed the flexibility of the sentencing process and the breadth of the DPP’s discretion.

2. Factual and Procedural Background

2.1 The underlying prosecution

The applicant, Mr Conor Greaney, was charged with assault causing harm contrary to s.3 of the Non‑Fatal Offences Against the Person Act 1997 (the “s.3 charge”) following an alleged unprovoked and serious assault in Cork city centre on 7 March 2024, in which the victim sustained a fractured ankle (para. 2).

He was brought before a special sitting of Cork District Court on 9 March 2024, refused bail, and remanded in custody for several months. On 13 March 2024, he informed his solicitor that he wished to plead guilty to the s.3 charge (para. 2).

The case was listed repeatedly before the District Court pending DPP directions. On 2 July 2024, the DPP directed that the matter proceed on indictment (para. 3). On that occasion, the applicant’s solicitor indicated that the applicant wished to proceed to the Circuit Criminal Court on a signed plea of guilty.

2.2 The DPP’s refusal of consent to a signed plea

Under s.13(2) and (2A) of the Criminal Procedure Act 1967 (as amended), an accused cannot be sent forward for sentence on a signed plea of guilty without the prosecutor’s consent. The DPP refused to give that consent (para. 3).

The applicant’s solicitor argued that this refusal deprived him of the mitigation normally attached to a signed plea. A book of evidence was then served and the applicant was sent forward for trial to the Cork Circuit Criminal Court on 7 August 2024, for an October 2024 hearing (para. 3).

2.3 The judicial review proceedings

In early September 2024, the applicant obtained leave to seek judicial review of the DPP’s refusal to consent to the signed plea (para. 4). The Circuit Court case was adjourned pending the outcome of this High Court challenge.

The core relief sought was:

An order of certiorari quashing the DPP’s refusal to consent to the applicant being sent forward on a signed plea of guilty (para. 9).
A declaration that this refusal breached the applicant’s constitutional right to a fair hearing and trial in due course of law.
Alternatively, a declaration that the DPP was obliged to provide reasons for her refusal (para. 9).
Further, a constitutional challenge to s.13(2A) of the 1967 Act, alleging that it unconstitutionally deprived the applicant of the opportunity to obtain a one‑third mitigation in sentence (para. 13).

3. Relevant Statutory Framework

3.1 Sending an accused forward for trial: s.4A Criminal Procedure Act 1967

Section 4A of the Criminal Procedure Act 1967 (as amended) provides the default rule that an accused charged with an indictable offence before the District Court must be sent forward to the trial court unless certain exceptions apply (e.g. summary disposal or the s.13 mechanism).

Crucially, s.4A(2) provides (para. 6):

“The accused shall not be sent forward for trial under subsection (1) without the consent of the prosecutor.”

If the prosecutor refuses consent, the District Court must strike out the proceedings in relation to that offence (s.4A(3)).

3.2 The signed plea procedure: s.13 Criminal Procedure Act 1967

Section 13 of the 1967 Act creates two main options where the accused wishes to plead guilty to an indictable offence:

Summary disposal – with the prosecutor’s consent, the District Court may deal with the offence summarily, imposing reduced maximum penalties (s.13(2)(a), (3)).
Sending forward for sentence on a signed plea – if the accused signs a plea of guilty, the District Court may send the accused directly to the court of trial for sentence (rather than for trial), under s.13(2)(b), but only “subject to subsection (2A)”.

Section 13(2A) is pivotal (para. 7):

“The accused shall not be sent forward for sentence under this section without the consent of the prosecutor.”

Thus, the DPP has an express statutory veto over the use of the signed plea mechanism.

3.3 Sentencing discounts for guilty pleas: s.29 Criminal Justice Act 1999

Section 29 of the Criminal Justice Act 1999 governs how sentencing courts may take account of a guilty plea (para. 8):

“In determining what sentence to pass on a person who has pleaded guilty to an offence, other than an offence for which the sentence is fixed by law, a court, if it considers it appropriate to do so, shall take into account:
(a) the stage in the proceedings for the offence at which the person indicated an intention to plead guilty, and
(b) the circumstances in which this indication was given.”

The section:

Gives courts a discretionary power, not a duty, to reduce sentence.
Focuses on the timing and circumstances of the indication of guilt, not the formal mode (e.g. signed plea vs oral plea).

4. Summary of the High Court’s Decision

The High Court refused all relief sought by the applicant (para. 36). The key holdings can be summarised as follows:

No entitlement to a fixed one‑third discount for signed pleas:
- The applicant’s case rested on a “flawed premise” (para. 19) that a signed plea as such must attract a one‑third mitigation in sentence, based on DPP v Cambridge [2019] IECA 133.
- There is no hard and fast rule; sentencing courts have wide discretion under s.29 CJA 1999, as reaffirmed in DPP v Faulkner [2024] IESC 16 and DPP v Olionu [2024] IECA 97 (paras. 19–25).
- In principle, there is “no distinction” in sentencing terms between a signed plea and an early “firm indication” of an intention to plead guilty (para. 21).
The DPP’s refusal of consent was not unlawful and was not reviewable on the facts:
- Decisions of the DPP are only reviewable in “exceptional circumstances” (para. 17, applying Murphy v Ireland [2014] 1 IR 198).
- No mala fides or improper motive was alleged; the claim rested instead on alleged “oppressiveness” or unfairness.
- The refusal to consent to a signed plea, especially to preserve the option of adding a more serious s.4 charge, was held to be a legitimate prosecutorial decision (paras. 16, 27).
No duty on the DPP to provide reasons in these circumstances:
- Although a reason was in fact provided in the DPP’s affidavit (para. 16), the Court reaffirmed that, save in exceptional cases, the DPP is not obliged to give reasons (para. 27, referring to Marques v DPP [2014] IEHC 443).
- No exceptional circumstances were found here.
The claim was premature (as a matter of ordinary criminal process and constitutional doctrine):
- Interference with ongoing criminal proceedings is only justified exceptionally; the primary duty to secure a fair trial lies with the trial court (para. 28, citing Byrne v DPP [2011] 1 IR 346).
- The applicant had not yet been sentenced, and the Court must assume that the Circuit Court will apply sentencing law correctly (para. 29).
The constitutional challenge to s.13(2A) was manifestly premature:
- Applying Galvin v DPP [2025] IESC 35, the Court held that the applicant’s constitutional attack on s.13(2A) was premature because no sentence had yet been imposed and no concrete disadvantage established (paras. 32–35).
- Counsel for the applicant ultimately did not press the constitutional claim in light of Galvin (para. 35).

5. Detailed Analysis

5.1 The heart of the applicant’s complaint: “loss” of a one‑third discount

The “nub” of the applicant’s case (para. 10) was that the DPP’s refusal to consent to a signed plea deprived him of the opportunity to gain a one‑third reduction in sentence. He relied on a reading of DPP v Cambridge as having “confirmed” that:

an accused “upon entering a signed plea is entitled to the benefit of mitigation of a third reduction in sentence” (para. 10, applicant’s characterisation), and
that refusal of the signed plea therefore removed access to this “entitlement”.

The applicant also argued that:

The DPP’s refusal amounted to an interference in the administration of justice and judicial discretion (para. 12).
There was no indication of other charges (such as under s.4) being contemplated, and thus no reasonable basis for withholding consent.
The DPP should have issued a reasoned decision.

In the alternative, he claimed that s.13(2A) itself was unconstitutional because it allowed the DPP to deprive him of the opportunity to obtain maximum sentencing mitigation (para. 13).

5.2 The DPP’s response

The DPP’s core positions were (paras. 15–16):

The District Judge was bound by the 1967 Act: without DPP consent, the applicant could not be sent forward for sentence on a signed plea (s.13(2A)); the DPP consented only to a return for trial (s.4A).
The DPP’s refusal to consent to a signed plea is not generally amenable to judicial review; no exceptional circumstances existed.
The Circuit Court retained full sentencing powers and discretion; Cambridge did not create a binding rule of automatic one‑third reduction for all signed pleas.
Legitimately, the DPP wished to preserve the option of adding a more serious charge of causing serious harm under s.4, having regard to the victim’s injuries (para. 16).

5.3 Reviewability of DPP decisions

5.3.1 The Murphy v Ireland test

The Court reaffirmed that the DPP’s decisions are generally only reviewable in exceptional circumstances. Citing O’Donnell J in Murphy v Ireland [2014] 1 IR 198 (para. 17), Ferriter J recalled that:

“A decision of the Director is reviewable if it can be demonstrated that it was reached mala fides or influenced by improper motive or improper policy, or other exceptional circumstances.”

There was no allegation of bad faith in this case. Instead, the applicant argued that the DPP’s powers cannot be exercised in a way that gives an “oppressive, unfair, or signal advantage” to the prosecution over the defence (para. 17, citing the discussion in Dunne, Judicial Review of Criminal Proceedings, 2nd ed., para. 11‑35).

5.3.2 Was the DPP’s refusal “oppressive” or unfair?

Ferriter J held that any apprehended disadvantage at sentencing was “not well founded as a matter of law” (para. 19). The applicant’s entire oppression argument depended on his alleged loss of a one‑third sentencing reduction. Once the Court rejected the idea of a legally guaranteed one‑third reduction for signed pleas, the foundation for “oppression” fell away.

The DPP’s stated reason – to preserve the option of adding a s.4 charge – was expressly accepted as a “perfectly legitimate” one (para. 27). The Court noted more generally that the DPP might legitimately refuse consent to a signed plea:

where further medical evidence is awaited to determine whether more serious charges are appropriate, or
where indictment time limits prevent full consideration of possible charges at District Court stage (para. 27).

Accordingly, no improper motive or oppressive use of power was established. The high threshold for judicial review of DPP decisions was not met.

5.4 Sentencing discounts for guilty pleas: Cambridge, Faulkner and Olionu

5.4.1 The applicant’s reliance on Cambridge

In DPP v Cambridge [2019] IECA 133, the Court of Appeal said (para. 11):

“we again take this opportunity of emphasising the special weight which should be attached to signed pleas whatever the state of the evidence. We think in the circumstances that the appropriate reduction from the headline sentence, because of the signed plea, should be in or about one third…”

The applicant treated this as having “confirmed” that a signed plea entitled him to a one‑third reduction (para. 10). Ferriter J rejected that reading. Cambridge was:

deciding what was “appropriate” on its own facts,
emphasising “special weight” for signed pleas, but
not creating a universal, rigid rule binding all sentencing judges in all circumstances.

5.4.2 Section 29 CJA 1999 and Faulkner

Ferriter J placed Cambridge within the broader statutory and appellate framework, particularly s.29 of the 1999 Act and the Supreme Court’s decision in DPP v Faulkner [2024] IESC 16. Quoting Charleton J at para. 44 (para. 19):

“[I]t is good sense that both timing and circumstance inform the degree of discount to a sentence which a plea of guilty, or firm indication, deserves. Hence, there are authorities that signing a plea of guilty while an indictable offence is being processed in the District Court may deserve up to a one-third reduction in the headline sentence; The People (DPP) v Cambridge [2019] IECA 133, The People (DPP) v O’Callaghan [2020] IECA 172. Nonetheless, every sentence should meet the gravity of the offending and the principle of proportionality prevails; The People (DPP) v Stubbins [2021] IECA 229.” (emphasis supplied)

Charleton J further explained (para. 45, cited at para. 20):

“Experience demonstrates that perhaps one-third discount may apply where there is an early indication and the circumstances are such as to enable a real choice on the part of the offender. Later pleas of guilty… will be deserving of a lesser mitigation … No clear or hard rules are either discernible or necessary. The pattern seems to indicate a variable, based on timing and circumstance, from a potential 33% to perhaps as low as 10%…”

Two points are critical:

The law recognises a range of discounts (roughly 10%–33%), depending on the timing and context; and
A “firm indication” of an intention to plead guilty can justify similar mitigation to a signed plea.

Ferriter J drew from this that:

There is no hard and fast rule requiring a one‑third discount for signed pleas.
There is no principled basis to distinguish, for sentencing purposes, between:
- a signed plea in the District Court, and
- a clear, early, firm indication at District Court stage that the accused intends to plead guilty (paras. 19–21, 24).

5.4.3 Olionu and the treatment of early indications

In DPP v Olionu [2024] IECA 97, Edwards J emphasised both individualised sentencing and the flexible treatment of signed pleas. At para. 57 (quoted at para. 22), he said:

“It would be inimical to any system of individualised sentencing that a sentencing court would be unable to take into account the circumstances in which a plea (including a signed plea) was offered… While we accept that an extra discount is, in general, afforded for having signed a plea in the District Court, we do not accept that there is any hard and fast rule as to the level of extra discount that must be afforded.”

In Olionu, because the appellant had indicated an intention to plead guilty at an early stage, he was “entitled to be treated as though he had signed a plea in the District Court” (para. 23). Ferriter J seized on this as confirming that:

it is the substance (timing and clarity) of the indication of guilt that matters most, not its formal label (paras. 23–24);
where a signed plea is procedurally unavailable (for example, due to refusal of DPP consent), an early and firm intention to plead guilty can attract equivalent mitigation.

5.4.4 Conclusion on the discount question

Ferriter J concluded (paras. 21, 24–25):

There is “no distinction in principle” in sentencing terms between a signed plea and an early indication of an intention to plead guilty.
There is no statutory or binding common-law rule elevating signed pleas to an automatic one‑third reduction.
The applicant’s attempt to convert a dictum in Cambridge into a fixed rule “flies in the face” of s.29 CJA 1999 and the sentencing jurisprudence.

Accordingly, the applicant’s fear of being legally bound to receive a lesser discount due to the DPP’s refusal of consent was unfounded.

5.5 The DPP’s duty (or lack thereof) to give reasons

Although a reason was provided in the prosecutor’s affidavit – namely the desire to keep open a potential s.4 “causing serious harm” charge (para. 16) – the Court addressed the more general legal point: is the DPP obliged to give reasons for refusing consent to a signed plea?

Ferriter J held (para. 27) that it is “well established” that, save in exceptional circumstances, the DPP is not required to give reasons for her decisions, citing Marques v DPP [2014] IEHC 443 and the broader commentary in Dunne’s text (para. 27).

He saw no exceptional circumstances here to justify a departure from that rule as regards the DPP’s exercise of her s.13(2A) discretion to refuse consent. Even when the DPP exercises a statutory power which has clear consequences for how the case reaches the trial court (e.g. via trial or via sentence-only), the starting point remains:

The DPP has broad discretion and institutional independence.
There is no routine obligation to explain specific prosecutorial choices to an accused.

The Court added (para. 27) that the reasons for refusing consent to a signed plea may be many and varied (e.g. awaiting further evidence, time pressures on indictments, or strategic assessment of possible charges). These decisions, absent some exceptional feature such as discrimination or mala fides, remain non‑justiciable.

5.6 Prematurity and deference to the trial court

5.6.1 Non-intervention in ongoing criminal proceedings

Ferriter J stressed that the High Court should be slow to intervene in the course of ongoing criminal proceedings. Citing O’Donnell J in Byrne v DPP [2011] 1 IR 346 (para. 28), he noted:

“The manner in which the Constitution contemplates that a fair trial is normally guaranteed, is through the trial and, if necessary, appeal processes of the Courts established under the Constitution… It is… entirely consistent with the constitutional order to observe that it will only be in exceptional cases, that superior courts should intervene and prohibit a trial…”

Applying that principle, Ferriter J held (paras. 28–30):

The applicant’s complaint centred on the future sentencing stage: he feared receiving a lesser discount than he might have obtained via a signed plea.
That sentencing had not yet occurred. The Circuit Court retained full discretion to:
- recognise the applicant’s very early and firm intention to plead guilty; and
- attach such weight to that fact as is appropriate in all the circumstances (para. 29).
The High Court should assume that the sentencing judge will apply the law correctly and fairly.

Thus, any intervention at this stage was premature and contrary to the Constitution’s envisaged sequence of trial, sentence, and (if necessary) appeal.

5.7 The constitutional challenge to s.13(2A)

5.7.1 The applicant’s constitutional argument

The applicant challenged s.13(2A) of the 1967 Act as unconstitutional on several bases (para. 31), including that it:

amounted to an unlawful interference with judicial discretion in sentencing, by allowing the DPP to control access to a (claimed) sentencing benefit; and
violated his right to trial in due course of law under Article 38.1 by depriving him of the chance to avail of a one‑third reduction linked to a signed plea.

5.7.2 The Galvin v DPP prematurity test

Counsel for the Attorney General argued that the constitutional challenge was “manifestly premature” in light of the Supreme Court’s decision in Galvin v DPP [2025] IESC 35 (para. 32). In Galvin, the applicant challenged a Finance Act provision that barred the use of the Probation of Offenders Act 1907 for certain offences. He did so before trial or sentencing. The Supreme Court held that:

in the absence of factual findings by the trial court, and
without any sentence having been imposed,

the constitutional issue was not yet ripe for adjudication.

Donnelly J set out several factors relevant to prematurity (para. 33), including:

(A) Whether the court has sufficient evidence before it to enable it to properly address the constitutional arguments in a reasonably concrete evidential context…
(B) Whether there would be interference with further administrative or judicial processes… whether the court is involved in an abstract and potentially unnecessary process…
(C) Whether there is a specific impact caused to the party seeking review by delaying the decision…
(D) Can it be said that the challenge is “imperatively required”?

In Galvin, the Supreme Court concluded that the applicant’s interests had not yet been affected or placed in imminent danger of being affected by the impugned sentencing restriction (para. 34).

5.7.3 Applying Galvin to Greaney

Ferriter J held that the same logic applied with full force to Mr Greaney’s challenge (para. 35):

No sentence had been imposed.
It was unknown how the Circuit Court would treat his early indication of guilt.
Any alleged disadvantage from s.13(2A) “may never in fact crystallise and, indeed, should not crystallise if the sentencing judge properly applies the applicable legal principles.”

The constitutional challenge was “classically premature” (para. 35). In light of Galvin, applicant’s counsel responsibly accepted that he could not press the constitutional claim (para. 35).

6. Simplifying the Key Legal Concepts

6.1 What is a “signed plea”?

A “signed plea” in this context refers to a formal written plea of guilty signed by the accused in the District Court under s.13 Criminal Procedure Act 1967. When:

the accused wishes to plead guilty to an indictable offence, and
the accused understands the charge and the facts alleged,

the District Court can:

either deal with the matter summarily (with prosecutor’s consent), or
send the accused forward for sentence only to the higher court if a signed plea is furnished – but only with the DPP’s consent (s.13(2)(b) and (2A)).

The signed plea mechanism is a procedural shortcut: it avoids a full trial in the Circuit Court and moves directly to sentencing there.

6.2 “Sent forward for trial” vs “sent forward for sentence”

Sent forward for trial (s.4A, Criminal Procedure Act 1967): the normal route for indictable offences. The accused goes to the Circuit Court or Central Criminal Court for a full trial on the merits, unless a guilty plea is entered at that stage.
Sent forward for sentence (s.13, Criminal Procedure Act 1967): available where the accused has already pleaded guilty in the District Court by signed plea and the DPP consents. The higher court’s role is confined to sentencing.

6.3 Guilty plea mitigation

Irish sentencing law recognises that a guilty plea can justify a reduced sentence because:

it saves court time and resources;
it spares victims and witnesses from having to give evidence;
it may show remorse and acceptance of responsibility.

However:

The discount is not automatic; s.29 CJA 1999 says the court may reduce the sentence “if it considers it appropriate”.
The timing and circumstances of the indication of guilt are key:
- the earlier and clearer the indication, the greater the potential mitigation;
- the later the plea (e.g. during trial or after witnesses have travelled/given evidence), the smaller the discount.
There is no absolute right to a specific percentage reduction; the appellate guidance speaks of a typical range (about 10%–33%).

6.4 “Prematurity” in constitutional and judicial review cases

A case is “premature” when the court is asked to decide constitutional or legality questions before the facts have sufficiently developed. In criminal matters, this often arises where:

the trial or sentencing has not yet occurred, and
the alleged infringement may never materialise, depending on how the trial court acts.

Galvin and Greaney together underscore that:

courts will not normally entertain pre‑emptive constitutional challenges to sentencing rules before conviction and sentence;
the trial and appeal process is the primary mechanism to vindicate fair trial rights.

6.5 Judicial review vs appeal

It is important to distinguish:

Appeal – challenges the correctness of the trial court’s decision on law and/or fact. Sentencing appeals argue that the sentence was wrong or excessive.
Judicial review – challenges the legality or fairness of processes and decisions (e.g. of the DPP or District Court), not the merits of the criminal charge itself, and is only available on limited grounds.

In Greaney, the applicant sought judicial review of the DPP’s pre‑trial decision, not an appeal from any sentence or conviction.

7. Impact and Broader Significance

7.1 For accused persons and defence practitioners

The decision clarifies that:

There is no legal entitlement to a one‑third reduction simply because an accused is sent forward on a signed plea.
An early, clear, and firm indication of an intention to plead guilty – even without a signed plea – can attract equivalent sentencing credit.
Defence practitioners should ensure that such early indications are explicitly recorded on the court record, so they may be relied upon at sentencing.
Challenges to DPP refusals of consent to signed pleas will face a high threshold; absent mala fides or serious unfairness, such decisions are unlikely to be judicially reviewed.

7.2 For the DPP and prosecutorial discretion

The judgment reinforces the breadth of the DPP’s discretion:

The DPP may legitimately refuse consent to a signed plea in order to preserve the option of pursuing more serious charges (e.g. s.4 causing serious harm), or for other proper prosecutorial reasons.
There is no general obligation to provide reasons for such refusals, and only exceptional circumstances will trigger a need to give reasons or open such a decision to review.
The High Court confirms that the DPP’s s.13(2A) discretion does not constitute an impermissible interference with the judicial function of sentencing.

7.3 For sentencing courts

From the sentencing perspective, Greaney consolidates existing appellate guidance:

Section 29 CJA 1999 provides a discretionary framework, emphasising timing and circumstances.
Judges should not treat sentencing discounts as fixed, mechanical percentages; proportionality and the gravity of the offending remain primary.
Signed pleas may, as a matter of practice, justify significant discounts, but they do not create rigid entitlements.
Where a signed plea was procedurally unavailable but the accused clearly signalled an early intention to plead guilty, that fact should be given similar weight, following Faulkner and Olionu.

7.4 For constitutional and administrative law

Greaney also has broader doctrinal implications:

It applies and strengthens the Galvin prematurity doctrine: constitutional attacks on sentencing-related provisions will usually not be adjudicated before conviction and sentence.
It reaffirms the limited justiciability of DPP decisions: courts will intervene only for mala fides, improper motive, improper policy, or comparable exceptional circumstances.
It rejects the notion that prosecution decisions which influence the procedural route (e.g. signed plea vs full trial) necessarily amount to an unconstitutional encroachment on the judicial sphere.

8. Conclusion

Greaney v DPP & Ors [2025] IEHC 731 is a significant High Court decision on the interaction between prosecutorial discretion, sentencing practice, and fair trial rights.

The Court held that:

The DPP’s refusal to consent to a signed plea under s.13(2A) did not unlawfully deprive the applicant of a sentencing benefit because there is no legal right to a one‑third reduction for signed pleas, nor any principled distinction between a signed plea and an early firm indication of an intention to plead guilty.
Sentencing courts retain a wide discretion under s.29 CJA 1999 to calibrate discounts based on timing and circumstances, within a broad but flexible range.
The DPP’s decision to preserve the option of a more serious charge was legitimate and neither oppressive nor subject to review on the facts of this case; no duty to provide reasons arose.
The challenge, including the constitutional attack on s.13(2A), was premature, given that no sentence had yet been imposed and any alleged disadvantage might never arise, especially if the Circuit Court applies the law correctly.

The case thus clarifies that the perceived “loss” of a signed-plea label does not, in law, translate into a loss of entitlement to a particular quantum of mitigation, and that prosecutorial discretion in consenting to signed pleas remains robust, subject only to exceptional review.