Where an offender is sentenced for discrete series of armed robbery offences committed on separate occasions, the principle of totality does not justify structuring sentences so that the later offences are effectively subsumed within the sentences for the earlier offences; some measure of accumulation is required to ensure the offender is punished for the discrete offences. Where the Henry guideline range includes a 10 per cent discount for a late plea of guilty, no more than 15 per cent should be allowed for a plea entered at the first opportunity; however, where the offence falls outside the guideline category, a full 25 per cent discount may be allowed provided the sentence bears an appropriate relationship to the guideline.
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