When a sentencing judge imposes a cumulative sentence on top of an activated suspended sentence, the totality principle requires explicit consideration of whether the aggregate sentence is just and appropriate in light of the total criminality. A failure to undertake this review, or an aggregate sentence so disproportionate as to compel an inference of error, will warrant appellate intervention. For a young offender convicted of multiple armed robberies of service stations with weapons but no actual violence, a total effective sentence of seven years (three years cumulative on four years activated) with parole eligibility at approximately one-third was appropriate, whereas eight years was manifestly excessive. The relationship between the 'crushing sentence' concept and the totality principle remains unresolved in Queensland.
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