Where a sentencing judge imposes identical sentences for offences voluntarily disclosed by an offender and for similar offences discovered independently, and makes no reference to R v Ellis principles in the sentencing remarks, an appellate court is justified in concluding that the voluntary disclosure was not taken into account, constituting sentencing error. An overall sentence resulting from successive accumulations may be manifestly excessive even where each individual sentence is within the available range, and the appropriate remedy is to reduce the degree of accumulation.
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