The principle of totality comprises two elements1:
(1) that all courts, when sentencing for more than a single offence, should pass a total sentence which reflects all the offending behaviour before it and is just and proportionate2; and
(2) it is usually impossible to arrive at a just and proportionate sentence for multiple offending simply by adding together notional single sentences: it is necessary to address the offending behaviour, together with the factors personal to the offender as a whole3.
There is no inflexible rule governing whether sentences should be structured as concurrent or consecutive components: the overriding principle is
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