Where a prisoner voluntarily confesses to an unsolved murder motivated by genuine contrition and waives immunity, a life sentence may still be appropriate but the non-parole period must reflect a significant discount to avoid a crushing sentence where avoidable, and to serve the public interest in encouraging confessions. The discount for voluntary disclosure under R v Ellis operates through the non-parole period where a life sentence is warranted. Totality and the crushing sentence principle are distinct concepts: a relatively short sentence may infringe totality without being crushing, and where a crushing sentence cannot be avoided, it does not infringe totality.
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