Discounts under ss 22 and 23 of the Crimes (Sentencing Procedure) Act 1999 (NSW) must be applied sequentially, not added together and applied as a combined total. Family hardship, even where the offender is the sole carer of multiple children, does not constitute 'highly exceptional circumstances' warranting a discrete additional measure of leniency where the offender knowingly engaged in serious criminal conduct for profit. A wholly suspended sentence for the principal of a heroin distribution syndicate, where subordinate co-offenders received full-time custody, is manifestly inadequate.
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