The Wong and Leung sentencing guideline range of five to seven years for low-level trafficable quantities of heroin applies to couriers and persons low in the importing hierarchy; offenders found to have a significantly higher role may receive sentences above that range without the sentence being manifestly excessive. The two-thirds convention for non-parole periods in Commonwealth cases remains a prima facie proportion, not a rigid rule. The Court declined to reconsider Studenikin and Kevenaar on the effect of the repeal of s 16G of the Crimes Act 1914 (Cth).
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