Crown prosecutors' descriptions of a defence case as 'palpable nonsense', 'absolute and utter nonsense', 'palpably laughable' and 'just rubbish' are inappropriate but will not necessarily occasion a miscarriage of justice where defence counsel addresses the comments vigorously and does not seek judicial directions. The totality principle permits partial accumulation of sentences for conspiracy to import drugs and a related proceeds of crime offence where the offences are legally and factually separate.
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