A combined sentence of imprisonment and a CCO must be assessed for manifest excess in its totality; it is impermissible to assign individual sentencing aims to different components or to compare the combined sentence duration with a possible term of imprisonment with a non-parole period. Where a court on appeal considers readjusting the components of a combined sentence, any variation increasing the duration of either component should be treated as a potentially more severe sentence requiring a s 281(3) warning.
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