A legislative amendment changing the jurisdictional classification of an offence (allowing summary disposal) that does not directly apply to the proceedings and does not alter the maximum penalty is not a relevant sentencing consideration, particularly where the offences were not plainly wrongly in the District Court. The totality principle need not be expressly articulated in detailed terms; it is sufficient if its application is discernible from the remarks on sentence as a whole and the structure of the sentence imposed.
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