Differences in criminal history, rehabilitation prospects, and remorse between co-offenders can justify different cumulation orders even where individual sentences are the same. The totality principle may lead to different cumulation results for co-offenders facing sentence for different numbers of offences, without infringing the parity principle. Where an applicant relies on [name withheld] principles of childhood deprivation, scant material placed before the sentencing judge will limit the weight that can be given to that factor.
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