The totality principle requires that total effective sentences for multiple offences across separate indictments bear a proper relationship to the overall criminality, and error may be implied from the sentencing outcome even where individual sentences are not challenged. A 20% discount for guilty pleas under s 9AA of the Sentencing Act 1995 (WA) is within the range open to a sentencing judge even where pleas are entered at a relatively late stage. The second limb of the totality principle (crushing sentence) is not breached where the offender will be aged 67 upon discharge.
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