Where a co-offender's sentence is reduced on appeal, the resulting increase in the differential between co-offenders' sentences may give rise to a justifiable sense of grievance even where the sentencing judge properly applied parity principles at first instance. The application of the totality principle to a co-offender's aggregate sentence is not a complete answer to a parity complaint; the court must compare all components of the sentences for all offences each offender is serving. A finding of manifest excess cannot be based on a single factor.
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