The sentencing categories developed in DPP (Cth) v De La Rosa for drug importation offences are not sentencing guidelines and a sentence falling outside the range identified for a particular category cannot, of itself, demonstrate error in the sentencing discretion. A combined discount of 45% for plea and assistance may be appropriate where the assistance was significant, useful, complete, reliable and timely, and the offender faces onerous custodial conditions. The question of manifest inadequacy remains whether there has been some misapplication of principle, not whether the sentence falls outside a particular category range.
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