Disregard for public safety (s 21A(2)(i)) is an inherent characteristic of the offences of ongoing supply, actual supply, and deemed supply of cocaine, and cannot be taken into account as an aggravating factor unless its nature or extent goes beyond what ordinarily might be expected. Planning and organisation (s 21A(2)(n)) is inherent in ongoing drug supply, and the mere fact that transactions were completed at a location away from where drugs were stored does not evidence an unusual degree of planning. An offence of deemed supply cannot form part of an ongoing drug supply charge under s 25A(1), which requires actual supply.
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