The standard non-parole period under Division 1A of Part 4 of the Crimes (Sentencing Procedure) Act 1999 retains relevance as a reference point even where the offence falls outside the middle range of objective seriousness. Sentencing judges must not treat the standard non-parole period as irrelevant once the offence is assessed as below the middle range. The factors relevant to objective seriousness are not confined to those in s 21A(1)(c) but embrace the full range of circumstances identified in R v Way. A non-parole period of 2 years (20% of the standard non-parole period of 10 years) for supply of nearly 1 kg of methylamphetamine at 84.5% purity was manifestly inadequate even for a young courier with strong subjective circumstances.
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