A sentencing judge may not increase the sentence on one count to reflect the total criminality of all offences; the correct approach is to find special circumstances and adjust commencement dates. An offender's denial of guilt and consequent exclusion from sex offender treatment programs, which effectively prevents release on parole, is not a mitigating factor in sentencing (following Reyes), though Hulme J's separate reasons question this position and suggest sentencing judges should more carefully consider the relativity between non-parole periods and balance of term for sex offenders who deny guilt.
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