A one-year difference in head sentence between co-offenders in a drug importation case may constitute unjustifiable disparity where the appellant has significantly lower culpability and substantially better mitigating circumstances than the co-offender who received the higher sentence. The anxiety or urgency in an offender's text messages does not form a safe basis to determine the offender's role in a criminal enterprise, although the messages may demonstrate a level of deference supporting an inference that one offender recruited or organised the other.
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