Where cumulative sentences for drug trafficking and related offences are imposed on top of existing sentences, the totality principle requires moderation of the individual sentences so that the overall effect is not crushing. A total cumulative sentence of 21 years and three months, requiring approximately 15 years before parole eligibility, was manifestly excessive for a three-month trafficking period by a recidivist offender. Separately, pre-sentence custody spent solely on remand for new offences after the expiry of prior sentences may be declarable notwithstanding R v Braeckmans, even where the combined effect of ss 209(1) and 211 of the Corrective Services Act 2006 (Qld) later reinstates a period of outstanding imprisonment from the prior sentences.
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