A ground of appeal asserting inadequacy of reasons or fact-finding in a judge-alone trial has little utility when coupled with an unreasonable verdict ground, because the appellate court's independent assessment of the evidence necessarily rectifies any deficiency. The definition of 'criminal group' in s 93S(1)(a) of the Crimes Act 1900 (NSW) requires identification of a single serious indictable offence from which all participants share the objective of obtaining material benefits; a series of disparate offences is insufficient. However, participants in a drug supply chain (vendor and purchaser who on-sells) can share such an objective where each derives material benefit from the same supply transaction. Money laundering under s 193B(2) does not require identification of specific money.
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