A finding of 'substantial involvement in supply' attracting the Clark principle (requiring exceptional circumstances for non-custodial sentences) requires evidence beyond deemed supply based on quantity alone; the mere possession of a trafficable quantity distributed across multiple bags does not, without more, establish trafficking in the sense of supply on more than one occasion. The correctness of the Clark principle itself was left open for future reconsideration in light of Hili v R.
The full text is available to signed-in members, including the 4 later cases that cite this judgment.
1 of the 4 citing cases carry a classified treatment. How each court treated it is available to signed-in members.