Duress as a mitigating factor in drug offences carries significantly reduced weight where the offender's initial involvement in criminal activity was voluntary and motivated by financial gain, the offender was unsupervised, and objective evidence (such as intercepted communications) reveals enthusiastic rather than reluctant participation. The standard non-parole period must guide the setting of the non-parole period, not the total sentence. Form 1 offences of considerable gravity must produce a substantial increase in sentence above that appropriate for the primary offence alone.
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