Where an offender contends that undercover police involvement diminished culpability, the onus falls on the offender to prove on the balance of probabilities that they were induced to commit offences they would not otherwise have been disposed to commit; it is not sufficient to merely raise the issue without calling evidence. The totality principle applies by analogy to prior completed sentences only in limited circumstances: where the offending is part of the same course of conduct, where rehabilitative benefits from the prior sentence justify leniency, or where there is a risk of institutionalisation. Where rehabilitation has been unsuccessful and the offender quickly reoffended, these rationales do not apply.
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