The totality principle, while applicable to serious violent offenders, must not undermine the legislative policy in ss 6D and 6E of the Sentencing Act 1991 requiring cumulation and prioritising community protection. There are no fixed percentages for cumulation above which a total effective sentence will be held manifestly excessive, and no predetermined ratios governing the relationship between head sentence and non-parole period. General deterrence is of fundamental importance in domestic violence cases, and courts should send an unequivocal message that perpetrators will receive lengthy imprisonment.
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