The totality principle applies to multiple environmental offences arising from a single course of conduct, including offences under different statutes (NP&W Act and NVC Act). Where the defendant is the sole shareholder and director of a corporate co-defendant, the penalty on the company effectively falls on the individual, which is a relevant sentencing consideration. A 25% discount for guilty pleas was appropriate where the utilitarian value was reduced because the element of knowledge would have been readily inferred from the defendant's prior commissioning of a species impact statement. Ongoing conservation obligations under a Property Agreement and s 118E orders are relevant to the quantum of fine.
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