A cumulative sentence of two years imprisonment for armed robbery counts, imposed upon an existing effective sentence of 13 years, does not offend the totality principle where the sentencing judge has substantively moderated the cumulative term. The same effective sentence may properly be imposed on co-offenders with different levels of involvement where countervailing factors (such as age differences, additional offences, and different totality considerations arising from different existing sentences) justify the same outcome.
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