A challenge to the length of an aggregate sentence for multiple offences that depends on an inference of implied error should be based on a breach of the totality principle, not on manifest excess. The lack of a pre-sentence report cannot itself be a discrete ground of appeal; at most it may reinforce a submission that the sentencing judge was not sufficiently advised of the facts. In drug trafficking cases involving large quantities of dangerous drugs, personal mitigating factors carry diminished weight where general deterrence is the dominant sentencing consideration.
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