The categories set out in DPP v De La Rosa for drug importation sentencing are of limited assistance and that decision is not a guideline judgment; sentencing judges should undertake a fact-specific analysis rather than seeking to place an offender within a particular category. Offences forming part of a single enterprise may nonetheless be separate discrete offences warranting accumulation of sentences, and the mere temporal relationship between offences does not mean the criminality of one encompasses the criminality of another.
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