A sentencing judge who considers whether an offender was involved in 'substantial drug trafficking' as a preliminary step before the sentencing exercise commits error, following the overruling of R v Clark in Parente v R. However, such error will not result in a different sentence on appeal where the sentence imposed is otherwise appropriate. The weight to be given to prior good character must be determined by reference to the circumstances of the offending conduct, not the type of offence, though factors such as planning and the importance of general deterrence may properly reduce the weight given to good character.
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