A prior conviction for a similar offence, even if old and minor, cannot be treated as a matter of 'serious aggravation' that raises the upper boundary of sentence; it is relevant only to where within the boundary set by objective circumstances the sentence should lie. The expression 'organised criminal activity' in s 21A(2)(n) conveys more than simply that the offence was planned; a low level of planning inherent in the offence type does not enliven the aggravating factor. However, sentencing errors do not necessarily require resentencing if the sentence remains within the appropriate range.
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