Drug 'rip-offs' that purport to be genuine deals involving more than the large commercial quantity of a prohibited drug are objectively serious offences, and it will only be in an exceptional case that a non-custodial sentence will be appropriate. Sentencing judges must address specific and general deterrence when sentencing for such offences. Extraordinary delay in sentencing proceedings caused by the sentencing judge may ground the exercise of the residual discretion not to intervene on a Crown appeal, even where manifest inadequacy is established.
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