The totality principle is not contravened where the combined sentence reflects the offender's very high objective criminality, having regard to the quantity of drugs involved and the offender's senior role in the chain of distribution.
Simpson J, Bell J
The parity principle is not engaged where co-offenders' roles are so fundamentally different — a senior organiser versus an intermediate courier — that meaningful comparison cannot be made. Separate drug transactions weeks apart involving separate quantities are properly characterised as distinct offences warranting cumulative sentences, not as one continuing course of criminality.
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Cases that have considered REGINA v HE
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Judicial Consideration (Chronological)