Voluntary cessation of criminal activity prior to arrest, combined with other subjective features such as age, established rehabilitation, and good character, may constitute exceptional circumstances justifying suspension of a sentence for substantial drug dealing under s 25A(1) of the Drug Misuse and Trafficking Act 1985. The 'financial or material reward' element of s 25A(1) may be satisfied by an ill-defined benefit such as relief from pressure to repay a debt, but where the reward is minimal, this reduces the objective seriousness of the offence.
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