When moderating cumulation in light of the totality principle, a sentencing judge is not required to confine moderation to sentences between presentments; moderation may occur within a presentment, between presentments, or both. There is no principle that where offending results in any injury to more than one victim, some cumulation must be provided for offences relating to each victim — cumulation must always be applied in light of the totality principle. In 'king-hit' cases, where there is a substantial disparity between the probable serious injury foreseen and the catastrophic injuries actually sustained, the sentencing judge must give full weight to the effect on the victim while being mindful that the severity of consequences should not swamp all other sentencing considerations.
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