The presumption of cumulation under s 6E of the Sentencing Act 1991 (Vic) for serious offenders must have more than a formal effect; sentencing judges must not undermine the legislative policy by applying the totality principle as if s 6E were not on the statute book. Childhood deprivation as a mitigating factor under Bugmy is not 'cancelled out' by the risk the offender poses to the community; both remain independently relevant sentencing considerations. Individual sentences that are lenient but not manifestly inadequate may still produce a manifestly inadequate total effective sentence where the cumulation orders fail to give proper effect to s 6E.
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