Sentencing judges must articulate the precise manner in which an offender's prior criminal record is taken into account under s 21A(2)(d) of the Crimes (Sentencing Procedure) Act 1999, applying the Veen (No 2) principles. A bare reference to the record as an 'aggravating factor' without explanation is unsatisfactory and may constitute error where the record is not capable of attracting the Veen (No 2) principles. The objective seriousness of drug supply offences is not to be assessed by reference to quantity and street value alone, but by reference to the broader factual context including evidence of an ongoing supply business.
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