A sentencing judge does not err by failing expressly to cite or apply DPP (Cth) v Maxwell's 'low reward drug' analysis where the judge has in fact taken into account the modest financial reward expected from the drug supply. The question whether Maxwell applies under the Drug Misuse and Trafficking Act 1985 (NSW) was left open, though the Court indicated it may be appropriate in some cases. An aggregate sentence of 8 years imprisonment (after 25% discount) for supply of 5.624 kg of GBL plus attempted supply of 584.3 g of GBL, with Form 1 offences including precursor possession, was upheld as not manifestly excessive.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.
2 of the 2 citing cases carry a classified treatment. How each court treated it is available to signed-in members.