R v BD does not establish a binding principle that removal of Sudafed tablets from packaging can never constitute a step in the process of manufacture of methylamphetamine under s 6 of the Drug Misuse and Trafficking Act 1985. Where the removal is done with the intention of using the contents to manufacture the drug, it may constitute such a step. The impossibility of manufacture from defective chemicals does not preclude conviction where the charge covers a lengthy period and the accused's involvement extended beyond the specific failed attempt.
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