Evidence of prior drug dealings between conspirators is admissible where it goes beyond mere propensity to show the criminal nature of the association, the reason for the conspiratorial agreement, and the terms of that agreement — even where the prior dealings may have involved a different drug from that charged. In a conspiracy to possess with intent to sell or supply, it is not necessary that the earlier transaction be shown to have involved the same drug as the subject of the conspiracy; what must be proved is that the subject agreement concerned the charged drug. The trial judge's discretion under s 637 of the Criminal Code (WA) regarding order of final addresses will not be disturbed on appeal absent demonstrated error of law, fact, or reasoning.
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