The totality principle is a fundamental sentencing obligation, not a mitigating factor, and a sentencing judge must apply it even where counsel fails to raise it. The principle applies even where the separate and later sentencing results from the offender remaining silent about earlier offending. Where there has been significant delay between offence and sentence, the sentencing judge must ask what additional penalty is required having regard to the sentence already imposed, taking into account all relevant circumstances including rehabilitation in the interim.
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