A Director's appeal against sentence under s 287 of the Criminal Procedure Act 2009 (Vic) is competent where it impugns orders for cumulation and concurrency producing the total effective sentence, provided the ground particularises which individual sentences or cumulation orders are attacked. Manifest inadequacy in sentence constitutes appealable 'error' within s 287, falling within the residual category identified in House v The King. The presumption of cumulation under s 6E of the Sentencing Act 1991 for serious offenders is intended to have more than a formal effect, and the totality principle is to an extent limited by that provision.
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