'Return' in the definition of 'supply' in s 3 of the Misuse of Drugs Act 1981 (WA) bears its ordinary English meaning of giving, taking or sending back, and does not require proof of a prearranged plan or bailment arrangement. A person who returns drugs to a supplier because they are unwanted is reintroducing the drugs into the supply chain and this falls within the mischief of the Act. Significant co-operation with authorities in drug cases must be reflected in a discount of appropriate magnitude.
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