When sentencing for multiple offences, the court must first determine the appropriate sentence for each individual offence, isolating the aggravating factors applicable to each, before considering questions of accumulation, concurrency, and totality. A sentencing judge who determines the structure of concurrent or cumulative sentences before properly assessing individual sentences commits error. On a Crown appeal, the principle of double jeopardy requires that re-sentencing produce a result somewhat less than would have been imposed at first instance, and the totality principle has particular force in this context.
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