A sentencing judge who imposes individual sentences and cumulation orders based on mechanical monetary thresholds, without differentiating between rolled-up and single counts, attempt and completed offences, or offences on the same day or against the same victim, infringes the totality principle. When resentencing for multiple offences, the preferred approach is to adjust cumulation orders rather than individual sentences. Attempt offences must receive lower sentences reflecting the lower statutory maximum.
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