Where pre-sentence custody is partly attributable to imprisonment for other offences, the totality principle from Mill v The Queen applies and the court may make the current sentence partly concurrent with the earlier sentence to respect that principle. Taking pre-sentence custody into account under s 63 of the Crimes (Sentencing) Act 2005 (ACT) does not require a full accounting of the period but only requires it to be taken into account to the extent that is fair in all the circumstances. The formulations in Hawkins v Hawkins ('very sparingly used') and Wronski v Raue ('good reason') are not materially different.
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