A courier in a drug trafficking operation who plays a limited role in planning will generally attract a significantly lesser sentence than the organiser/planner, and a failure to provide adequate disparity between their sentences may constitute manifest excess and a breach of parity principles. A non-parole period of 60% of the head sentence is not inconsistent with a stated intention to allow a 'considerable gap' between head sentence and non-parole period, as there is no usual or standard non-parole period ratio.
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