The aggravating factor of planned or organised criminal activity under s 21A(2)(n) of the Crimes (Sentencing Procedure) Act can be established in drug courier cases where the planning involves interstate travel, coded communications, hotel arrangements, and concealment measures, as these exceed the degree of planning inherent in a drug supply offence. A sentence of 6 years (3 years non-parole) for a courier supplying 478g of MDMA (just below the large commercial quantity) was within range.
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