Commission of an importation offence while in custody serving a sentence for similar offending is a significant aggravating factor that underscores the need for personal deterrence and constitutes a distinguishing factor for parity purposes. A sentencing judge is entitled to find differences in 'directional type behaviour' between co-offenders notwithstanding a Crown concession of broad equivalence in moral culpability, provided the finding is based on a comparison of the objective conduct.
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