Where an offender is convicted of trafficking in different drugs found at the same location, the co-location of the drugs does not diminish the separate criminality of each offence for the purposes of the totality principle, and significant cumulation may be warranted. The Court of Appeal may correct a sentencing judge's failure to declare pre-sentence detention under s 280(3)(b) of the Criminal Procedure Act 2009 even where leave to appeal is refused.
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