The totality principle requires that where multiple sentences are imposed by different courts, the overall effect must not be disproportionate to the total criminality or crushing. Total cumulation between sentences on separate indictments and between those sentences and earlier sentences requires justification and will be set aside where it produces a manifestly excessive result. A sentencing judge is under no obligation to impose a sentence within the range put forward by the prosecution in a MacNeil-Brown submission, nor to give reasons for departing from that range.
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