Where an offender commits assault offences against multiple victims in separate and distinct attacks, wholly concurrent sentences are likely to infringe the first limb of the totality principle, even where the attacks are temporally and geographically close. The one transaction rule does not apply to offences against different victims because the offending is not a single invasion of the same legally protected interest. However, the degree of an offender's participation in each offence is a significant factor: a co-offender with a lesser role in one of the attacks may properly receive wholly concurrent sentences.
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