Where two offences arise from the same episode but are different in nature and manner of commission, the totality principle does not permit the criminality of one offence to be treated as substantially reflected in the sentence for the other. The intentional penetration of a child's anus causing internal injury is a very serious offence even where the offender is not sexually motivated. The significant aspect of penetration is that it was long enough and deep enough to cause injury, not its duration. The need to protect children from sexual assault is not lessened by the absence of sexual motivation.
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