Where an offender commits manslaughter while on conditional liberty (bail and a suspended sentence), the commission of the offence on conditional liberty weighs heavily against partial accumulation of sentences, and the sentencing judge is not required to partially accumulate even where the combined effective non-parole period is lengthy. The totality principle does not require partial concurrence where the offences are discrete and independent acts of criminality and partial accumulation would not adequately reflect the criminality of the manslaughter offence.
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