The uplift in sentencing practices for trafficking in commercial quantities of drugs of dependence called for in Gregory and Fernando is not displaced by the High Court's emphasis on individualised sentencing in Dalgliesh. The uplifted sentencing practice remains a relevant factor in every sentencing exercise of this kind, though it is not a controlling factor. For commercial quantity methylamphetamine trafficking where the quantity approaches the large commercial quantity threshold and the offender is a senior participant in a syndicate, a sentence of approximately 23% of the maximum penalty is manifestly inadequate; a sentence of approximately 39% of the maximum (9 years 9 months of 25 years) was substituted.
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