When applying the totality principle, a sentencing court must take into account the period of imprisonment to be served on account of breach of parole, not merely the sentences imposed for the current offences. The proposition that the severity of imprisonment increases exponentially with length (from Jarvis v The Queen) is obiter and should not be treated as established sentencing law. The totality principle is simply a requirement that the total sentence bear a proper relationship to the overall criminality involved.
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