Where co-offenders are assessed as having the same criminality but one has a materially stronger subjective case (no prior record, mental health condition, isolation), a differentiation of only 1-2 months in sentence is so disproportionate as to constitute House v R error. The case illustrates that while lack of prior convictions carries less weight in drug importation offences, it and other subjective factors must still receive meaningful recognition in the sentence imposed.
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