The case confirms that an individual sentence of 12 months' imprisonment for escaping lawful custody under s 146 of the Criminal Code (WA) is within range where the escape was motivated by evading discovery of a substantial quantity of drugs and the offender remained at large for two weeks engaging in further criminal activity. A total effective sentence of 6 years' imprisonment for sustained drug dealing over 2½ months involving multiple incidents of possession of methylamphetamine with intent to sell or supply, escaping custody, and possessing stolen property does not infringe the totality principle.
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