The Carey direction that possession may be otherwise than for supply is confined to cases where drugs are held as a mere custodian for return to an owner; it does not apply where the accused received drugs from one person for the purpose of passing them to another, as such a person is a link in a chain of supply. When assessing objective seriousness for the standard non-parole period, the sentencing judge must consider factors beyond the s 21A criteria, including the offender's role (courier vs principal), the quantity of drug relative to the commercial range, and purity. Prior convictions listed in s 21A(2)(d) must not be treated as aggravating the offence, consistent with the common law principle in Veen (No 2).
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