The principles in Pearce v The Queen concerning accumulation and concurrency have no application where an aggregate sentence is used; the only relevant question is whether the aggregate sentence reflects the totality of the criminality. An offender's position within a drug supply hierarchy remains an important consideration in assessing objective seriousness, and characterisations such as 'mid-range' and 'slightly above mid-range' are necessarily subjective and impressionistic rather than empirical measurements.
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