Life imprisonment under s 61(2) of the Crimes (Sentencing Procedure) Act 1999 is not warranted for a retail-level drug supply operation involving aggregated small sales to a small group of users, even where the total quantity substantially exceeds the large commercial quantity threshold and the offender has prior drug convictions. The conditions in s 61(2), particularly 'high degree of planning and organisation' and 'high degree of purity', require evidence commensurate with those descriptions and are not satisfied merely by the existence of a functioning retail drug operation. R v Chung is distinguishable where the offender occupied a senior position in an international criminal organisation dealing in wholesale quantities.
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