A sentencing judge's failure to expressly advert to special circumstances under the Sentencing Act 1989 does not automatically constitute appealable error, but where the end result warrants an inference that the material was not correctly collated and analysed, the appellate court may intervene. The totality principle does not require reduction of sentence where offences are independent crimes committed on different occasions. An appellate court may vary the apportionment between minimum and additional terms while maintaining the overall sentence where special circumstances, particularly youth and the prospect of extended continuous custody, warrant a longer period of supervised release.
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