Drug supply offences and precursor possession offences involve distinct criminality from manufacturing offences even where they arise from the same criminal enterprise, and require significant notional accumulation rather than substantial concurrency. Indicative sentences for offences assessed as 'well above the mid-range' must bear a rational relationship to the maximum penalty guidepost, and must adequately reflect Form 1 offences. Section 68A of the Crimes (Appeal and Review) Act 2001 (NSW) abolishes the double jeopardy discount on Crown sentence appeals, though the court may still fix a sentence at the lower end of the appropriate range.
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