In sentencing bare couriers for heroin importation, the level and quality of co-operation with authorities will predominantly influence the sentence, rather than the plea of guilty or lack of prior convictions. Sentencing judges must carefully distinguish between discounts for past co-operation and future co-operation under s 21E of the Crimes Act 1914 (Cth), and must not fix the discount for promised future co-operation higher than warranted. Judicially expressed sentencing guidelines such as those in R v Wong serve only as a 'sounding board' or 'check' and must not fetter the sentencing discretion.
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