The totality principle takes priority over concurrency and accumulation principles when sentencing for multiple offences; an apparent failure to apply concurrency/accumulation principles is not necessarily erroneous if the total sentence appropriately reflects the total criminality. Assertions that offences are 'among the worst examples' must be supported by analysis and reasons, not bare assertion. The question whether a total sentence is manifestly inadequate is answered by assessing whether the totality of the sentence adequately reflects the total criminality, not by asking whether sentences have been appropriately accumulated.
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