The case confirms that sentencing judges are not bound by agreed facts as to an offender's role and may make their own assessment, provided procedural fairness is afforded. However, the dissent of N Adams J highlights the risk of error where a sentencing judge speculates about matters not in evidence or effectively reverses the onus of proof regarding an offender's role. The case provides a comprehensive survey of sentencing for hydroponic cannabis cultivation offences and emphasises the legislative intention behind the 2006 amendments for substantial sentences. The majority upheld an aggregate sentence of 13 years and 4 months for six offences involving seven properties, which was the highest sentence recorded for this class of offence.
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