There is no general principle that an offer to supply a prohibited drug is necessarily less objectively serious than an actual supply; the relative criminality depends on the facts and circumstances of each case. Where an offender relies on drug or gambling addiction as relevant to objective seriousness, the evidence must be of sufficient quality to establish a causal connection between the addiction and the offending. Where accumulated sentences result in a non-parole period exceeding the statutory ratio, the sentencing judge must address whether special circumstances exist if such a finding has been requested.
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