There is no general rule that sentences for offences committed on the same day or in the same criminal enterprise should be served concurrently; the question is whether the criminality of one offence can be encompassed in the criminality of the other. Where an offender has committed other serious offences of a similar nature after the offences being sentenced, little or no significance can be given to prior good character. When accumulating sentences with sentences imposed by another court, the sentencing judge must apply the totality principle and consider whether the accumulation itself gives rise to special circumstances.
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