The totality principle is a limitation upon excess (not a floor ensuring sufficiency), and may be given effect by making sentences wholly or partly concurrent — this is the preferred course. Wholesale concurrency of sentences for discrete offences is not necessarily erroneous where it reflects the application of the totality principle rather than a finding of common elements between offences. On Crown appeals, manifest inadequacy must be clearly demonstrated, with the attitude of restraint applying equally to the overall result produced by the totality principle as to individual sentences.
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