Section 21A(2)(n) of the Crimes (Sentencing Procedure) Act 1999 requires that the offence form part of a more extensive criminal undertaking; the mere fact that an offence was planned does not engage the subsection. However, an offence that is not part of organised criminal activity may still be characterised as 'professionally planned' under the Ponfield guideline, which is a separate aggravating consideration going to the offender's level of criminality.
The full text is available to signed-in members, including the 13 later cases that cite this judgment.
3 of the 13 citing cases carry a classified treatment. How each court treated it is available to signed-in members.