The totality principle does not require that an aggregate sentence be 'crushing' before it can be found to be inappropriately long, but a total effective sentence of 6 years for 63 offences including 12 aggravated burglaries committed over approximately 10 weeks was within the appropriate sentencing range. A sentencing 'starting point' is not the sentence and cannot be the subject of an appeal ground alleging manifest excess. The question whether the exponentiality theory or a simpler proportionality rationale underpins the totality principle remains unresolved in Western Australia.
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