The former approach of structuring sentences across multiple counts to reflect total criminality, with less regard to individual sentence appropriateness, should no longer be followed as it masks error and leads to anomalies. Where convictions on some counts are quashed, the remaining sentence on other counts must be assessed for adequacy standing alone. Credit may be given for time served under quashed sentences where the circumstances are analogous to R v Tolmie. A Crown appeal against sentence may proceed before the Crown decides whether to pursue a retrial on quashed counts.
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