When sentencing for offences from the same period as offences already dealt with, the correct approach to totality is to assess whether the combined sentencing outcome (earlier sentence plus current sentence) encompasses the whole of the criminality, not to reverse engineer the earlier sentence. A community corrections order may be appropriate even for serious child sexual assault offences where the offender has already served a custodial sentence for similar offending from the same period, particularly where the offender is elderly, in poor health, and has demonstrated sustained rehabilitation.
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