The case identifies the specific factors relevant to assessing objective seriousness of unauthorised possession of firearms in circumstances of aggravation under s 51D(2) of the Firearms Act 1996, including the number and type of firearms, purpose of possession, relationship to other criminal activity, location and security of storage, and history of aggressive behaviour. Where a co-offender's liability for firearms possession arises primarily from joint ownership and occupation of premises rather than active involvement, the objective seriousness is at the lower end of the range. The totality principle requires that where drug cultivation and supply offences are closely connected (the cultivation being for the purpose of supply), sentences should be largely concurrent.
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