Individual sentences for sexual offences against children that pay insufficient regard to maximum penalties prescribed by the legislature may be found manifestly inadequate on Crown appeal. The totality principle, while correctly enunciated, may be erroneously applied if the aggregate sentence does not adequately reflect the total criminality of systematic offending against multiple victims over an extended period. Extra-curial punishment in the form of violent assault in custody resulting in serious injury is a relevant consideration on resentencing.
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