The totality principle applies whenever a prisoner is being sentenced while already serving another sentence, regardless of whether the offences are related in time or nature. A sentencing judge must not treat the determination of the appropriate sentence and the question of cumulation as rigidly separate issues; the overall effect of the combined sentences must be assessed as a whole. Where cumulative sentences produce a disproportionate total, the appropriate course may be to maintain the cumulative order but reduce the head sentence.
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