The Court of Appeal held that a total effective sentence of 5 years' imprisonment for possession of 48.6 g of methylamphetamine and 46.57 g of heroin with intent to return them to a known drug dealer did not breach the totality principle, even where the offender was a bailee rather than a commercial participant. The Court confirmed that the 'one transaction rule' is not a rule but merely a working principle subsumed within the first limb of the totality principle, and that courts are not required to impose concurrent sentences for offences committed at the same time. Personal deterrence remained relevant notwithstanding the offender's non-commercial role, given her prior imprisonment for similar offending and continuing drug use.
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