In the 2014 case of McMillan v Police NZHC 150 the High Court of New Zealand held that the sentencing judge’s allowance for participation in restorative justice was too low ‘in the context of the appellant’s very evident remorse, his offer of substantial reparation and the views of those victims who had commented directly on the issue of imprisonment’ (para. 60). An allowance of 20 per cent was considered appropriate (para. 61).