The instinctive synthesis approach required by Markarian does not prohibit a sentencing judge from identifying the extent of a reduction for a plea of guilty or the effect of totality, provided this is done in the interests of transparency. However, a sentencing judge must not fix notional starting sentences based solely on objective criminality and then sequentially deduct for subjective factors. The totality principle operates as a final check and must not be used as the vehicle for first considering matters such as youth and rehabilitation that should have been weighed earlier. The combined reduction for pleas of guilty, contrition, remorse and cooperation should not ordinarily exceed one-third. For well-planned and large-scale armed hold-ups of banks, the standard range of six to eight years per offence identified in R v Place applies, though youth and immaturity may justify a sentence at the lower end of that range.
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