The sentencing groupings in De La Rosa for drug importation offences are not a guideline judgment and cannot be used mechanically to demonstrate manifest excess by placing an offender within a particular group and arguing the sentence exceeds that group's range. A sentencing judge's treatment of duress satisfies the requirements of Tiknius v R if the remarks contain 'some analysis, and an expression of conclusions' regarding the impact of duress on objective gravity and moral culpability. Hardship arising from incarceration in a foreign country remains of strictly limited significance where the offender deliberately came to Australia to commit a serious crime.
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