Where multiple sexual offences against a child arise from a single continuing episode of criminality, the totality principle requires concurrent sentences even where the individual sentence for the principal offence is at the top of the available range. A sentence of six years six months with a four-year non-parole period for a single act of cunnilingus on a nine-year-old child (s 66A, maximum 20 years) was at the top of the range but within it for an offender who pleaded not guilty and showed no remorse.
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