A sentencing judge dealing with multiple offences must fix an appropriate sentence for each offence having regard to its individual circumstances before considering questions of cumulation, concurrence and totality. A global approach that imposes identical concurrent sentences without regard to the distinct facts of each count masks error and may result in invalid sentences exceeding statutory maxima. Where an offender is already serving sentences for other offences, the principle of totality requires adjustment but does not justify a sentence that is manifestly inadequate when measured against the overall criminality.
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