When assessing parity between co-offenders, the court must consider all components of the sentence for all offences each offender is serving, not merely the indicative sentence for the common offence. The application of the totality principle to a co-offender is not a complete answer to a parity complaint; where the totality principle results in significant leniency for a co-offender sentenced for multiple offences, a justifiable sense of grievance may arise for a co-offender sentenced for a single shared offence even where the sentence is not manifestly excessive in isolation.
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