When a sentencing judge applies the Nagy approach of incorporating overall criminality into a head sentence, there is no requirement to expressly identify which sentences have been inflated and to what extent. The arithmetic methodology suggested in R v Bowditch at [23] is not a sentencing principle and is inconsistent with the instinctive synthesis approach endorsed by the High Court in Barbaro and Markarian. A sentence of seven years and six months for street-level methylamphetamine trafficking over four months, incorporating 26 offences including grievous bodily harm to a police officer, with parole at one-third, is within the proper exercise of the sentencing discretion.
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