The principles from Gregory v The Queen regarding sentences 'well into double figures' for serious trafficking in commercial quantities should not be applied to low-level trafficking cases, particularly in light of the High Court's emphasis in DPP v Dalgliesh on individualised sentencing and the VSCA's qualification in Lytras. A non-parole period of approximately 74% of the head sentence for an offender who has never previously been on parole invites scrutiny and requires explanation by the sentencing judge.
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