Where multiple offences arise from a single sequence of events sharing common aggravating features (here, aggravated burglary, rape and sexual assault all occurring during a single nocturnal home invasion), the principle of totality requires that cumulation orders not produce a total effective sentence disproportionate to the aggregate criminality. The individual sentences on each charge were not manifestly excessive but the cumulation was. The Court also confirmed that in assessing aggravated burglary seriousness, the focus should be on aggravating features present rather than reasoning by subtraction from absent features.
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