An appeal against conviction after a guilty plea will only be permitted in extreme circumstances where the material shows a real question about the guilt of the accused; a case that rises no higher than showing that evidence should have been excluded is insufficient. A typographical error in the date on a controlled operations certificate under s 15M of the Crimes Act 1914 (Cth) does not invalidate the certificate where the intent is plain and the error obvious. For sentencing, a head sentence of 3.5 years for a person low in the hierarchy of a cocaine importation involving a trafficable quantity is manifestly inadequate; the preponderance of sentences for such offenders lies in the range of 6 to 9 years.
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