A sentencing judge is not required to refer expressly to the principle of totality in sentencing remarks, nor to expressly state that the total effective sentence has been reviewed after orders for cumulation, provided the reasoning is implicit in the orders made. Multiple drug trafficking and possession offences detected by police on the same day through search warrants at different properties do not necessarily constitute a single transaction requiring concurrency, particularly where different drugs are involved at different locations. The Worboyes principle regarding the increased utilitarian value of a guilty plea during the COVID-19 pandemic does not require a sentencing judge to calculate a pre-pandemic discount and then apply an additional reduction.
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