The totality principle under s 9(2)(l) of the Penalties and Sentences Act 1992 (Qld) applies where an offender is serving an existing sentence in the community on parole, not only where the offender is in actual custody. The statement in R v Beattie at [21] does not preclude a sentencing judge from considering a hypothetical sentence for all offending at one time in an appropriate case; the error identified in Beattie was specific to the facts of that case where the totality principle had no application at all.
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