Sentencing ranges discussed in individual manslaughter cases such as R v Sebo do not establish general ranges applicable to all manslaughter cases; the offence is susceptible to a very wide range of sentences. A sentencing judge may properly impose a global sentence that includes additional time for separate assault charges to which an offender pleads guilty at the sentencing hearing, provided the judge distinguishes between prior criminal history already punished and the new charges. Separate offences committed at different times should not be made concurrent merely because they form part of a course of conduct.
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