Individual sentences of 11 years for trafficking in a large commercial quantity of heroin (just over the threshold) by a mid-level syndicate member who pleaded guilty were within range, but a total effective sentence of 19 years for four trafficking charges over six weeks required moderation to 16 years under the totality principle, given the applicant's clean record, early guilty plea and extraordinary delay. The case confirms the post-Gregory trend of upward sentencing for commercial and large commercial quantity drug trafficking in Victoria.
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