The principle in R v Filipponi that general deterrence militates strongly against suspension of sentences for drug trafficking does not preclude immediate release on recognizance where the offender has demonstrated significant rehabilitation, including sustained drug-free status, positive correctional services reports, and engagement in counselling and volunteer work. Interstate District Court sentencing decisions that have not been reviewed by an appellate court provide only limited assistance for consistency purposes, particularly where the quantity of the substance differs or is unknown.
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