The totality principle from Mill v The Queen has only limited relevance where the earlier sentence was imposed more than four years prior, would have expired but for the offender's misconduct, and s 156A of the Penalties and Sentences Act 1992 (Qld) requires cumulative sentencing. A sentence of six and a half years imprisonment for armed robbery in company with personal violence is within range for an offender with an extensive history of similar offending who commits the offence 12 days after release on parole.
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