Where co-offenders are engaged in the same criminal enterprise, a sentence two and a half times greater than that of a co-offender whose role was active and significant may give rise to a justifiable sense of grievance, even where the more heavily sentenced offender was the controlling figure charged with a more serious offence. The case also provides a survey of sentencing patterns for ongoing supply of heroin under s 25A(1) of the Drug Misuse and Trafficking Act 1985.
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