For sentencing under s 51D(2) of the Firearms Act 1996 (NSW), where firearms are not held for sale or storage for third parties and are not connected with other criminal activity, a starting sentence of approximately 7 years 7 months (before plea discount) for nine unregistered firearms including four prohibited firearms is manifestly excessive. The appropriate range for such non-commercial possession, informed by Taylor and Weaver, is significantly lower. The distinction between commercial/criminal purpose possession and non-commercial possession is a material sentencing factor.
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