A total effective sentence of 7 years 1 month for four series of armed robbery, motor vehicle theft and arson committed while on parole, served concurrently with existing sentences, infringed the first limb of the totality principle as not a just and appropriate measure of total criminality. The appropriate sentence was 9 years 1 month. Setting fire to stolen vehicles used in armed robberies magnifies the seriousness of the armed robbery offences.
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