When sentencing co-offenders for multiple federal offences, the degree of accumulation between sentences must be justified by reference to differences in the offenders' circumstances; where head sentences already reflect differential criminality, the totality principle cannot justify unexplained differential accumulation. A single non-parole period for multiple federal sentences must commence from the first day of the first sentence imposed, and a recognisance release order cannot be made for individual sentences where the aggregate exceeds 3 years.
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