A non-parole period of approximately 70% of the head sentence is unexceptional where there is a strong case for specific deterrence, an extensive criminal record, and guarded prospects of rehabilitation, and does not invite the scrutiny contemplated in R v VZ. The totality principle, where an earlier sentence has already been served, requires the prior sentences and time spent in custody to be taken into account as part of the offender's circumstances, but does not require the sentencing judge to identify what total sentence would have been imposed had all offending been before the court at the time of first sentencing.
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