The totality principle requires that where multiple serious sexual offences are committed within hours of each other by a juvenile offender, the extent of accumulation must reflect the overall criminality rather than simply aggregating individual sentences. Fresh evidence of a disease diagnosed after sentencing but present at the time of sentence may be received on appeal, but where the prognosis is favourable and prison medical treatment has been appropriate, the added burden of illness does not necessarily warrant a reduction in the non parole period.
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