The Wong sentencing guideline for drug importation couriers and persons low in the hierarchy does not apply where the offender has not been shown to be either a courier or low in the hierarchy. There is not a binary distinction between principals/high in hierarchy and couriers/low in hierarchy; significant participation may be revealed without disclosing full details of the offender's role. More onerous conditions of imprisonment caused by an extended appeal process are relevant to reducing the non-parole period.
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