The rule in Nikodjevic requiring a base sentence for cumulation does not apply in its strict form when sentencing across multiple presentments; the sentencing judge may take the largest sentence from any presentment as the base and cumulate upon it. The De Simoni principle does not prohibit taking into account aggravating circumstances that would constitute a less serious uncharged offence where those circumstances are inextricably intertwined with the charged offences; it is a matter of fairness and degree. A total effective sentence of 13 years (including unexpired parole) for a 27-year-old offender who committed 56 burglaries while on parole and then fired a loaded pistol at police officers during arrest was not a crushing sentence.
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