Possess Drug of Dependence

Cannabis on a Person's Hand
Possess drug of dependence is an offence contrary to section 73 of the Drugs, Poisons and Controlled Substances Act 1981 (‘the Act’).

The offence has two elements that the Prosecution must prove beyond reasonable doubt.

  • That the substance in question was a drug of dependence; and
  • That the accused possessed that substance.

It is important for a lot of people to avoid a conviction for drugs as it can impact on their ability to travel. The diversion program is often suitable for possession of small quantities of drugs when it is a first offence.

Examples of Possess Drug of Dependence
  • A person found with a small bag of an illicit drug in their pocket or bag
  • A person found with a small bag of an illicit drug in their car
  • A person found with a small quantity of illicit drug in their home
Questions in cases like this
  • Was the substance a drug?
  • Where was the substance found?
  • Was the substance found in your possession?
Possible Defences: Possess Drug of Dependence

Often defences revolve around the issue of intent as to whether the accused intended to possess the drug in question. There are also often factual disputes about the circumstances in which the drugs were possessed. Other defences available include factual dispute, duress, wrongful identification, mental impairment, honest and reasonable mistake or belief or necessity may apply.

Maximum penalty and court that deals with this charge

This charge is usually dealt with in the Magistrates’ Court.

The maximum penalty for this offence is a fine of up to 30 penalty units (around $5,000) or 1 year imprisonment.

What is the legal definition of Possess Drug of Dependence?

Drug of Dependence
Section 4 of the Drugs, Poisons and Controlled Substances Act 1981 (‘DPCSA’) defines a drug of dependence as a natural or synthetic drug listed in Schedule 11 to the Act.

Possession
There are three ways the prosecution can prove that an accused possessed a drug of dependence:

  1. By demonstrating that the accused intentionally had the drug in his/her custody, or under his or her control;1
  2. By relying on the deeming provision in section 5 of the DPCSA and proving that the illicit drug was in the car, or on land or premises occupied and controlled by the accused; or
  3. By relying on the deeming provision in the DPCSA, and proving that the accused used, enjoyed or controlled the drug.
Legislation

Possess drug of dependence is an offence under section 73 of the DPCSA.

Elements: Possess Drug of Dependence

We will look at each element in detail:

That the substance in question was a drug of dependence

Section 4 of the Drugs Act outlines substances which are said to be a drug of dependence. This includes:

  • Any form of the drugs specified in Parts 1 and 3 of Schedule Eleven to the Act, whether natural or synthetic;
  • The derivatives and isomers of the drugs specified in Parts 1 and 3 of Schedule Eleven to the Act;
  • The salt of the abovementioned drugs, derivatives and isomers;
  • Any substances that are included in the classes of drugs specified above; and
  • The fresh or dried parts of the plants specified in Part 2 of Schedule Eleven.

Click here to visit Schedule 11 of the Drugs Act.

Further, unusable portions of a drug (such as the stems, roots and stalks of the cannabis plant) are still considered to be drugs of dependence, so long as they fit within the definition specified by section 4.1

That the accused possessed that substance

The Prosecution can prove Possess Drug of Dependence for the purposes of this element by relying on the common law definition of possession. Common law possession involves the physical control with an intent to possess the drug allegedly possessed.

The conduct element

This requires the Prosecution to prove that a drug of dependence was in the Accused possession or physical in their control.2 A person does not need to be carrying the drug on their person to satisfy this element. They do however have to have custody or control over it. It is not uncommon for substances to be found in a person’s room whilst a warrant is executed for unrelated matters or even in a person’s car. In the first instance, a bedroom is a location where a person has manual custody and in the second, the substance is within reach of the Accused. This is said to be in their custody and within their control.3

“Was the drug in your custody or control?”
The mental element

In determining the mental element required, an inference can be drawn from all of the evidence available as to the Accused’s intention.

Common law possession requires the prosecution to prove that the accused intended to possess a drug of dependence. The prosecution does not need to prove that the accused intended to possess the particular drug in question, they only need to prove that the accused intended to possess a drug of dependence.4

Intention can be shown in variety of ways including admission by the Accused. It is also possible to infer an intention to possess a drug of dependence from proof that the accused knew of the existence and nature of the substance possessed.5 Awareness that there is real chance that a prohibited substance was possessed can satisfy the mental element required.6

Higher Court

Sentencing in the higher courts

From 1 July 2013 to 30 June 2018, there were a total of 60 cases (1,252 charges) that were heard in the higher courts of Victoria for the charge of Possess Drug of Dependence. Most of these cases resulted in imprisonment (46.7%) but other forms of sentencing were also imposed:

  • Fine – 18.3%
  • Community Correction Order – 13.3%
  • Adjourned Undertaking/Discharge/Dismissal – 13.3%
  • Wholly Suspended Sentence – 5%
  • Partially Suspended Sentence – 3.3%

Majority of those who were sent to prison received a term of less than a year (71.4%). The highest term imposed was between 2 and 3 years but this was also the least frequently imposed at only 3.6% of those who were sent to prison.

For the fines, majority were sentenced to an amount that was less than $1,000 (54.6%). The highest amount given was between $2,000 and $5,000 but this was also the least frequently imposed at only 9.1% of those received fines.2

Please note that suspended sentences were abolished in the higher courts earlier than that of the Magistrates’ Court, and therefore all offences committed on or after 1 September 2013 will not have this available as a sentencing option.3

Sentencing in the Magistrates’ Courts

The Magistrates’ Courts of Victoria have imposed various penalties for different forms of Possess Drug of Dependence from 1 July 2013 to 30 June 2016.

Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Alprazolam
Number of Cases: 80 (81 charges)

  • Community Correction Order – 31.3%
  • Imprisonment – 26.3%
  • Fine – 26.3%
  • Adjourned Undertaking/Discharge/Dismissal – 10%
  • Wholly Suspended Sentence – 6.3%
Most Commonly Imposed CCO Term: 12 < 18 months (40.7% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (3.7%, non-aggregate)
Most Commonly Imposed Prison Term: 3 < 6 months and 12< 18 months (28.6% respectively of those who received prison terms)
Longest Prison Term: 24 < 36 months (4.8%)4

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Amphetamines
Number of Cases: 3,191 (3,441 charges)

  • Fine – 26.7%
  • Imprisonment – 26.4%
  • Community Correction Order – 26.2%
  • Adjourned Undertaking/Discharge/Dismissal – 11.7%
  • Wholly Suspended Sentence – 6.1%
  • Partially Suspended Sentence – 2.1%
  • Other – 0.5%
  • Youth Justice Centre Order – 0.3%
Most Commonly Imposed Fine: $500 < $1,000 (30.4% of those who received aggregate fines)
Highest Fine Imposed: $5,000 < $10,000 (0.5%, aggregate)
Most Commonly Imposed Prison Term: < 3 months (30.8% of those who received prison terms)
Longest Prison Term Imposed: 36+ months (1.0%)5

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Anabolic Steroids
Number of Cases: 219 (258 charges)

  • Fine – 28.3%
  • Imprisonment – 27.4%
  • Community Correction Order – 25.6%
  • Adjourned Undertaking/Discharge/Dismissal – 8.7%
  • Wholly Suspended Sentence – 6.9%
  • Partially Suspended Sentence – 1.8%
  • Other – 1.4%
Most Commonly Imposed Fine: $1,000 < $2,000 (35.4% of those who received aggregate fines)
Highest Fine Imposed: $4,000 < $5,000 (2.1%, aggregate)
Most Commonly Imposed Prison Term: 6 < 12 months (26.7% of those who received prison terms)
Longest Prison Term Imposed: 36+ months (1.7%)6

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Cannabis
Number of Cases: 10,349 (11,566 charges)

  • Fine – 34.6%
  • Community Correction Order – 24.2%
  • Imprisonment – 19.0%
  • Adjourned Undertaking/Discharge/Dismissal – 15.9%
  • Wholly Suspended Sentence – 4.4%
  • Partially Suspended Sentence – 1.2%
  • Youth Justice Centre Order – 0.3%
  • Other – 0.3%
Most Commonly Imposed Fine: $500 < $1,000 (29.8% of those who received aggregate fines)
Highest Fine Imposed: $10,000 < $20,000 (0.1%, aggregate)
Most Commonly Imposed CCO Term: 12 < 18 months (50.1% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (6.5%, non-aggregate)7

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Cocaine
Number of Cases: 367 (375 charges)

  • Fine – 29.4%
  • Community Correction Order – 29.2%
  • Imprisonment – 24.0%
  • Adjourned Undertaking/Discharge/Dismissal – 11.7%
  • Wholly Suspended Sentence – 4.6%
  • Partially Suspended Sentence – 0.5%
  • Youth Justice Centre Order – 0.3%
  • Other – 0.3%
Most Commonly Imposed Fine: $500 < $1,000 (27.4% of those who received aggregate fines)
Highest Fine Imposed: $10,000 < $20,000 (1.7%, aggregate)
Most Commonly Imposed CCO Term: 12 < 18 months (56.1% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (8.3%, non-aggregate)8

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Diazepam
Number of Cases: 143 (147 charges)

  • Imprisonment – 32.2%
  • Community Correction Order – 30.8%
  • Fine – 18.9%
  • Adjourned Undertaking/Discharge/Dismissal – 11.2%
  • Wholly Suspended Sentence – 4.9%
  • Partially Suspended Sentence – 2.1%
Most Commonly Imposed Prison Term: 3 < 6 months (32.6% of those who received prison terms)
Longest Prison Term: 36+ months (2.2%)
Most Commonly Imposed CCO Term: 12 < 18 months (56.9% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (2.0%, non-aggregate)9

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Ecstasy
Number of Cases: 1,844 (1,953 charges)

  • Community Correction Order – 33.5%
  • Imprisonment – 23.5%
  • Fine – 21.8%
  • Adjourned Undertaking/Discharge/Dismissal – 14.4%
  • Wholly Suspended Sentence – 4.3%
  • Partially Suspended Sentence – 1.8%
  • Other – 0.5%
  • Youth Justice Centre Order – 0.2%
Most Commonly Imposed CCO Term: 12 < 18 months (55.3% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (5.1%, non-aggregate)
Most Commonly Imposed Prison Term: < 3 months (31.9% of those who received prison terms)
Longest Prison Term: 36+ months (0.7%)10

 
Magistrates' Court
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess GHB
Number of Cases: 1,069 cases (1,188 charges)

  • Community Correction Order – 29.9%
  • Imprisonment – 28.8%
  • Fine – 21.1%
  • Adjourned Undertaking/Discharge/Dismissal – 13.1%
  • Wholly Suspended Sentence – 4.1%
  • Other – 1.6%
  • Partially Suspended Sentence – 1.1%
  • Youth Justice Centre Order – 0.2%
Most Commonly Imposed CCO Term: 12 < 18 months (51.2% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (5.3%, non-aggregate)
Most Commonly Imposed Prison Term: < 3 months (31.8% of those who received prison terms)
Longest Prison Term: 36+ months (0.7%)11

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Hallucinogen
Number of Cases: 73 (75 charges)

  • Community Correction Order – 37.0%
  • Fine – 24.7%
  • Adjourned Undertaking/Discharge/Dismissal – 21.9%
  • Imprisonment – 11.0%
  • Wholly Suspended Sentence – 5.5%
Most Commonly Imposed CCO Term: 12 < 18 months (48.4% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (3.2%, non-aggregate)
Most Commonly Imposed Fine: $1,000 < $2,000 (33.3% of those who received aggregate fines)
Highest Fine Imposed: $2,000 < $3,000 (9.5%, aggregate)12

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Heroin
Number of Cases: 1,848 (2,144 charges)

  • Imprisonment – 32.0%
  • Fine – 23.7%
  • Community Correction Order – 23.1%
  • Adjourned Undertaking/Discharge/Dismissal – 13.5%
  • Wholly Suspended Sentence – 5.0%
  • Partially Suspended Sentence – 1.8%
  • Other – 0.9%
  • Youth Justice Centre Order – 0.1%
Most Commonly Imposed Prison Term: < 3 months (36.4% of those who received prison terms)
Longest Prison Term: 36+ months (0.7%)
Most Commonly Imposed Fine: $500 < $1,000 (30.1% of those who received aggregate fines)
Highest Fine Imposed: $5,000 < $10,000 (0.2%, aggregate)13

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Ketamine
Number of Cases: 75 cases (76 charges)

  • Adjourned Undertaking/Discharge/Dismissal – 34.7%
  • Community Correction Order – 28.0%
  • Fine – 21.3%
  • Imprisonment – 8.0%
  • Wholly Suspended Sentence – 4.0%
  • Partially Suspended Sentence – 1.3%
  • Youth Justice Centre Order – 1.3%
  • Other – 1.3%
Most Commonly Imposed CCO Term: 12 < 18 months (44.0% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (4.0%, non-aggregate)
Most Commonly Imposed Fine: $1,000 < $2,000 (40.0% of those who received aggregate fines)
Highest Fine Imposed: $5,000 < $10,000 (6.7%, aggregate)14

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess LSD
Number of Cases: 161 (163 charges)

  • Community Correction Order – 34.8%
  • Imprisonment – 21.7%
  • Fine – 21.7%
  • Adjourned Undertaking/Discharge/Dismissal – 16.2%
  • Wholly Suspended Sentence – 2.5%
  • Partially Suspended Sentence – 1.2%
  • Youth Justice Centre Order – 0.6%
  • Other – 1.2%
Most Commonly Imposed CCO Term: 12 < 18 months (64.6% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (1.5%, non-aggregate)
Most Commonly Imposed Prison Term: < 3 months (40.0% of those who received prison terms)
Longest Prison Term: 24 < 36 months (2.9%)15

 
Call Doogue + George
 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Methylamphetamine
Number of Cases: 7,138 (8,302 charges)

  • Community Correction Order – 29.6%
  • Imprisonment – 28.3%
  • Fine – 24.7%
  • Adjourned Undertaking/Discharge/Dismissal – 11.1%
  • Wholly Suspended Sentence – 3.9%
  • Partially Suspended Sentence – 1.4%
  • Other – 0.7%
  • Youth Justice Centre Order – 0.3%
Most Commonly Imposed CCO Term: 12 < 18 months (52.7% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (6.6%, non-aggregate)
Most Commonly Imposed Prison Term: < 3 months (32.7% of those who received prison terms)
Longest Prison Term: 36+ months (0.6%)16

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Morphine
Number of Cases: 48 (50 charges)

  • Community Correction Order – 33.3%
  • Imprisonment – 29.2%
  • Fine – 22.9%
  • Adjourned Undertaking/Discharge/Dismissal – 10.4%
  • Wholly Suspended Sentence – 4.2%
Most Commonly Imposed CCO Term: 12 < 18 months (41.2% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (11.8%, non-aggregate)
Most Commonly Imposed Prison Term: < 3 months (35.7% of those who received prison terms)
Longest Prison Term: 18 < 24 months (14.3%)17

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Oxycodone
Number of Cases: 106+ (109 charges)

  • Imprisonment – 42.5%
  • Community Correction Order – 32.1%
  • Fine – 12.3%
  • Adjourned Undertaking/Discharge/Dismissal – 9.4%
  • Wholly Suspended Sentence – 3.8%
Most Commonly Imposed Prison Term: 3 < 6 months (26.7% of those who received prison terms)
Longest Prison Term: 24 < 36 months (6.7%)
Most Commonly Imposed CCO Term: 12 < 18 months (45.5% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (13.6%, non-aggregate)18

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Prescribed Drugs
Number of Cases: 1,596 (2,186)

  • Community Correction Order – 29.0%
  • Imprisonment – 26.3%
  • Fine – 25.1%
  • Adjourned Undertaking/Discharge/Dismissal – 11.0%
  • Wholly Suspended Sentence – 5.5%
  • Partially Suspended Sentence – 1.8%
  • Other – 1.0%
  • Youth Justice Centre Order – 0.4%
Most Commonly Imposed CCO Term: 12 < 18 months (47.8% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (7.8%, non-aggregate)
Most Commonly Imposed Prison Term: 3 < 6 months (32.7% of those who received prison terms)
Longest Prison Term: 36+ months (1.2%)19

 
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Testosterone
Number of Cases: 53 (60 charges)

  • Fine – 35.9%
  • Community Correction Order – 24.5%
  • Imprisonment – 18.9%
  • Adjourned Undertaking/Discharge/Dismissal – 9.4%
  • Wholly Suspended Sentence – 7.6%
  • Partially Suspended Sentence – 3.8%
Most Commonly Imposed Fine: $2,000 < $3,000 (24.1% of those who received aggregate fines)
Highest Fine Imposed: $4,000 < $5,000 (10.3%, aggregate)
Most Commonly Imposed CCO Term: 12 < 18 months (50.0% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 18 < 24 months (21.4%, non-aggregate)20

 
Imprisonment
Drugs, Poisons And Controlled Substances Act 1981 (Vic) s 73(1) – Possess Other Drugs
Number of Cases: 2,615 (3,571 charges)

  • Imprisonment – 32.5%
  • Community Correction Order – 27.7%
  • Fine – 21.8%
  • Adjourned Undertaking/Discharge/Dismissal – 9.6%
  • Wholly Suspended Sentence – 5.1%
  • Partially Suspended Sentence – 1.8%
  • Other – 1.2%
  • Youth Justice Centre Order – 0.5%
Most Commonly Imposed Prison Term: “< 3 months" and "3 < 6 months" (30.5%, respectively, of those who received prison terms)
Longest Prison Term: 36+ months (0.7%)
Most Commonly Imposed CCO Term: 12 < 18 months (51.0% of those who received non-aggregate CCOs)
Longest CCO Term Imposed: 24+ months (80.0%, non-aggregate)21

 
Please note that suspended sentences were abolished in Victoria for all offences committed on or after 1 September 2014.22
 
In a trial, the questions a judge will ask the jury to consider are:

  1. Was the substance in question a “drug of dependence”?
    (Consider – [insert name of drug] a drug of dependence.
    If yes, then he will ask question 2.
    If no, then the accused is not guilty of Possess Drug of Dependence.
  2. Did the Accused possess the substance in question?
    • 2.1 Was the substance physically in the Accused’s custody, or otherwise under the Accused’s control?
      If yes, then go to 2.2
      If no, then the accused is not guilty of Possess Drug of Dependence.
    • 2.2 Did the Accused intend to possess the drug of dependence?
      (Consider – Can you infer from all the evidence that the Accused intended to have custody or control of a drug of dependence?
      If yes, then the Accused is guilty of Possess Drug of Dependence.
      Is no, then the Accused is not guilty of Possess Drug of Dependence.
Other important resources
Check out some of the criminal cases we’ve defended in court involving the charge of Possess Drug of Dependence:

 



[1] He Kaw Teh v R (1985) 157 CLR 523; R v Maio [1989] VR 281.
[2] Sentencing Advisory Council. “SACStat Higher Courts – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess a drug of dependence.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/higher_courts/HC_9719_73_1.2.html (accessed August, 15, 2019).
[3] Sentencing Advisory Council. “Abolished Sentencing Orders.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/about-sentencing/abolished-sentencing-orders (accessed August, 15, 2019).
[4] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess alprazolam.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.html (accessed August 16, 2019).
[5] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess amphetamines.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.2.html (accessed August 16, 2019).
[6] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess anabolic steroids.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.3.html (accessed August 16, 2019).
[7] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess cannabis.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.4.html (accessed August 16, 2019).
[8] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess cocaine.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.5.html (accessed August 16, 2019).
[9] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess diazepam.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.6.html (accessed August 16, 2019).
[10] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess ecstasy.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.7.html (accessed August 16, 2019).
[11] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess GHB.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.8.html (accessed August 16, 2019).
[12] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess hallucinogen.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.9.html (accessed August 16, 2019).
[13] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess heroin.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.10.html (accessed August 16, 2019).
[14] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess ketamine.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.11.html (accessed August 16, 2019).
[15] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess LSD.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.12.html (accessed August 16, 2019).
[16] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess methylamphetamine.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.13.html (accessed August 16, 2019).
[17] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess morphine.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.14.html (accessed August 16, 2019).
[18] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess oxycodone.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.15.html (accessed August 16, 2019).
[19] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess prescribed drugs.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.16.html (accessed August 16, 2019).
[20] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess testosterone.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.17.html (accessed August 16, 2019).
[21] Sentencing Advisory Council. “SAC Statistics – Drugs, Poisons And Controlled Substances Act 1981 (Vic): s 73(1) – possess a drug of dependence (other).” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/sacstat/magistrates_court/9719_73_1.18.html (accessed August 16, 2019).
[22] Sentencing Advisory Council. “Abolished Sentencing Orders.” SentencingCouncil.vic.gov.au. https://www.sentencingcouncil.vic.gov.au/about-sentencing/abolished-sentencing-orders (accessed August 16, 2019).