16 Sept 1988
The Court held that although the totality principle applies, the aggravating factor of offending while on bail justified not ordering concurrency; nonetheless the aggregate criminality did not warrant four years and the second sentence was reduced to 6 months (to run consecutively), producing a total effective sentence of 2.5 years.
26 Nov 1985
Given the substantial quantity of drugs, presence of trafficking paraphernalia, the probation report undermining genuine remorse, prior convictions and failure of prior detention treatment, the non‑custodial Drug Addiction Treatment Centre order was manifestly inadequate; the Court set aside that order and imposed immediate imprisonment of 3 years, applying CHAN Chi-ming tariff as the starting point but moderating on review.
27 Oct 1982
Where seized material contains esters of morphine and there is evidence or agreement that it can be converted into a larger quantity of saleable salts, the court may apply CHAN Chi-ming sentencing guidelines to the saleable quantity (via notional conversion or tariff adjustment); however esters and salts are distinct for sentencing and the trial judge must give proper credit for a guilty plea — failure to do so justifies reduction of sentence.