Evidence that an accused was the 'target' of a police operation is not inadmissible per se, particularly where the fact of targeting is obvious from the nature of the surveillance evidence admitted. Evidence of a third party's subsequent drug dealing activities may be admissible as circumstantial evidence relevant to the contents of packages supplied by the accused, the accused's knowledge, and the interpretation of recorded conversations. While it is undesirable to refer to an accused as the 'target' of a police operation, this does not necessarily result in a miscarriage of justice where the fact is otherwise apparent.
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