A total effective sentence of 8 years' imprisonment for three counts of manufacturing/attempting to manufacture methylamphetamine (with persistent offending while on bail), together with multiple drug supply offences and aggravated burglaries, does not infringe the first limb of the totality principle. Earlier cases involving multiple manufacturing counts (such as Lim and Abela) are now considered lenient and sentences for methylamphetamine manufacturing must be firmed up to reflect the increasing prevalence and danger of the offence.
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