Section 16(3B) of the Sentencing Act 1991 (Vic) does not dictate that new sentences must be served after the parole sentence; rather, s 17(1) provides that sentences commence on the day imposed, and s 15(1) determines the order of service. The totality principle requires relativity between the totality of criminality and the totality of sentences including the parole sentence, but must not undermine the legislative policy of s 16(3B). Discrete episodes of armed robbery involving separate victims require some degree of cumulation to reflect the seriousness and persistence of criminality. The question of whether double jeopardy on Crown appeals requires sentencing at the lower end of the range was left open.
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