Where an offender is serving time under an earlier sentence due to breach of parole by further offending, the totality principle does not require the later sentencing court to reduce the later sentence by the precise amount of time already served; rather, it requires some amelioration to avoid a crushing sentence while recognising that the earlier sentence represents punishment for separate offending. A starting point of 12-13 years imprisonment is within the appropriate range for trafficking in methylamphetamine at a wholesale level over 18 months to a customer base of 30 drug dealers.
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