The Gregory v The Queen sentencing uplift for commercial quantity drug trafficking remains a relevant factor in the sentencing exercise after DPP v Dalgliesh, but must not be treated as a determinative or controlling factor; it is one consideration to be balanced against all other sentencing factors in an individualised sentencing exercise. A sentencing judge may find an offender was the principal in a drug enterprise where the evidence of the offender's personal involvement is strong and there is no objective evidence of involvement by any other criminally-associated person.
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