An offender who is a key organiser of an ongoing conspiracy involving multiple importations of heroin, operating at a senior level largely unsupervised, falls within the 'worst case' category warranting life imprisonment even if not at the very apex of the organisation. The fact that co-offenders received lesser sentences due to the erroneous application of s 16G of the Crimes Act (Cth) does not give rise to a justifiable sense of grievance. The decision in R v Kelleher regarding reduction of non-parole periods for unavailability of remissions does not apply to life sentences following Lee Vanit v The Queen.
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