The non-parole period for Commonwealth drug importation offences must be determined by reference to all relevant circumstances, not just those favourable to the offender, and there is no fixed ratio between head sentence and non-parole period. The De La Rosa categories remain non-binding and it is an error to sentence by reference to the category into which an offence might fall. A courier's lower position in a drug importation hierarchy does not entitle the offender to special leniency, as the courier's role is essential to effecting the importation.
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