The totality principle applies by analogy where, but for delay not attributable to the offender, the offender would still have been serving a sentence in prison at the time of sentencing for an earlier offence. Demonstrated rehabilitation on parole buttresses rather than undermines the rationale for the totality principle. A sentencing judge must give proper weight to the exponential nature of combined sentences for similar criminal conduct and to rehabilitation efforts, even in cases of significant drug trafficking where general deterrence is a weighty consideration. The question whether the totality principle directly applies where an offender is on parole but not in custody was left open.
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