The orthodox approach to totality in sentencing for multiple offences requires the sentencing judge to first impose appropriate and proportionate individual sentences and then adjust the total by making sentences wholly or partially concurrent, rather than moderating individual sentences downward and then cumulating. Departure from this approach is only warranted where some special feature of the case requires it. Where a sentencing judge moderates individual sentences for totality purposes, the resulting cumulation must be sufficient to produce an appropriate total effective sentence, and token cumulation (such as one month for a child pornography charge) will not give adequate effect to deterrence.
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