A sentencing judge is not obliged to make independent inquiries into the nature of an offender's prior offending when that information is not provided by the parties; the adversarial system places that responsibility on counsel. Where delay between offence and arrest results in intervening sentences, the totality principle cannot be properly applied without information about the intervening offences being placed before the court. Emphasis on the standard non-parole period in accordance with the pre-Muldrock approach in Way does not necessarily constitute Muldrock error where the finding on objective seriousness did not deflect the judge onto an erroneous course.
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