Where the evidence does not permit the precise position of an offender within a criminal hierarchy to be established, the sentencing focus must be upon the degree of criminality of the acts performed and their importance in accomplishing the organisation's criminal purpose. Offenders who are less than forthcoming about their roles cannot complain about limited findings as to their position. The principle in R v Adams that it is incongruous to reduce penalty for separation from overseas family where the offender came to Australia for the dominant purpose of committing a serious crime was confirmed and applied.
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