Sentences of 3 years for trafficking commercial quantities of drugs and 6-7 years for trafficking large commercial quantities of MDMA were held to be manifestly inadequate, with the Court describing them as 'extraordinarily lenient'. Parity with unappealed co-offender sentences constrains the extent to which the Court of Appeal can increase sentences on a Crown appeal. A Crown appellant may rely on appeal on matters not expressly raised at the plea hearing if those matters were known to the defence and 'necessarily inherent in the issues to be decided'.
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