Following the High Court's overruling of the guideline judgment in R v Wong and Leung, sentencing for Commonwealth drug importation offences must proceed by reference to the court's own assessment of the relevant statutory provisions and prior authority rather than the guideline ranges. The discount for a plea of guilty should vary with the utilitarian benefit of the plea; a 25% discount is not warranted where the Crown case is capable of easy and short proof. An offender's role above that of a mere courier must be reflected in a higher sentence. The usual non-parole period range for Commonwealth offences is 60-66.6% of the head sentence.
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