For cultivation of a large commercial quantity of cannabis by enhanced indoor means under s 23(2)(a) of the Drug Misuse and Trafficking Act 1985, a non-parole period of approximately 3 years with a balance of term of 2 years is prima facie not manifestly excessive where the offender's role is at the lower end of the scale and the number of plants is in the range of 200-300. A significantly higher sentence (non-parole period of 5 years) may be justified where the offender is the sole entrepreneur with total involvement in all aspects of the enterprise and has a prior like conviction.
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