A sentence of 4 years' imprisonment (with a 3-year non-parole period) for trafficking 8.3 grams of heroin (non-commercial quantity) is within range for a recidivist offender with two prior trafficking convictions who conducted an organised trafficking operation. The quantity trafficked is a significant but not determinative factor in sentencing, and recidivism, organisation, specific deterrence and community protection may justify a substantially higher sentence than would be imposed on a first offender for the same quantity. The appendix provides a useful comparative table of recent sentencing decisions for trafficking in less than a commercial quantity.
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