The totality principle requiring a sentencing judge to take into account an existing sentence (as stated in Mill, Gordon, Beattie and LAE) is not engaged where the prior sentence has been completed in full before the sentencing hearing. Pre-sentence custody that does not fall within s 159A(1) because the offender was held for multiple sets of proceedings may still be taken into account as a matter of sentencing discretion, and the allowance need not equal the entirety of the pre-sentence custody.
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