Complete concurrency is inappropriate where an offender has trafficked in two separate large quantities of drugs involving different courses of conduct, even where the offences arise from the same broader criminal enterprise. A total effective sentence of nine years with a seven-year non-parole period for two counts of trafficking in a commercial quantity of amphetamine (involving approximately 10 pounds and 22 kilograms respectively, with the offender acting as the Victorian distribution manager) falls well within the available sentencing range where the maximum penalty is 25 years per count.
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