The Gregory sentencing uplift for commercial quantity drug trafficking applies to trafficking in BD notwithstanding the lower financial reward compared to drugs such as heroin and methylamphetamine. The lower reward is a relevant but not determinative factor, particularly where the quantity trafficked is at the highest end of the scale. A non-custodial sentence (CCO) remains available for CQ trafficking where the offender has no prior convictions, did not offend on bail, and has made exceptional rehabilitation progress, as the sentencing purposes of punishment and rehabilitation can be achieved simultaneously through onerous CCO conditions.
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