When fixing a non-parole period in circumstances where a substantial proportion of the total imprisonment consists of activated unexpired parole, the sentencing judge must give adequate weight to the total time the offender will actually spend in custody, including time on remand and the effect of the activated parole period. A non-parole period representing approximately 83% of the effective total period of imprisonment was held manifestly excessive where the offender had already spent most of his adult life in custody. The totality principle can only reduce the head sentence to be imposed, not the quantum of the activated unexpired parole period.
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