The totality principle does not authorise inflating the sentence for one offence to reflect the criminality of other unrelated offences being sentenced at the same time. The primary guiding principle in sentencing is proportionality between the offence and the sentence imposed. Subsequent unrelated offences may be considered as part of the offender's antecedents but should not be used to increase the sentence beyond what is proportionate to the offence in question. The question of whether the totality principle extends to permit inflation for unrelated concurrent offences was left open by Fryberg J.
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