The totality principle does not require that subsequent sentences be reduced to the point where they effectively undermine a mandatory minimum non-parole period for murder. Where an offender is serving a mandatory minimum, there is a limit to the extent to which subsequent sentences can be ameliorated by reference to totality, and an appropriate balance must be struck. An extension of time to appeal exceeding four years requires an exceptional or substantial explanation, and a bare claim of depression and drug withdrawal unsupported by medical evidence and contradicted by the applicant's demonstrated capacity to instruct lawyers on other matters during the same period is insufficient.
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