The totality principle is not excluded merely because a prior sentence has expired by the date of sentencing, particularly where the offender was serving the prior sentence at the time of the sentence hearing and the offending is of the same character. The extent of backdating a sentence to achieve partial concurrency with a prior sentence is within the sentencing judge's discretion and will not constitute House v The King error unless the discretion has miscarried. Recidivist offending in discrete episodes separated by detection and punishment is not apt to engage the totality principle to any great benefit in reduction of sentence.
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