When sentencing for multiple offences, the proper approach is to fix appropriate individual sentences proportionate to each offence first, then order cumulation or concurrency to achieve a proportionate total effective sentence — not to moderate individual sentences downward to accommodate totality. While some reduction of individual sentences may be permissible, any reduction should not take the original sentence outside the range appropriate to the gravity of the offence. The question of how the totality principle is to be reconciled with the statutory presumption of cumulation under s 6E of the Sentencing Act 1991 for serious sexual offenders was expressly left open.
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