A total effective sentence of 25 years and 5 months' imprisonment for 24 offences of rape, intentionally causing injury, threats to kill, false imprisonment and assault against four intimate partners over 20 years was held not manifestly inadequate, notwithstanding that the individual sentences and cumulation orders were lenient. The totality principle is not obliterated by the serious offender provisions in Part 2A of the Sentencing Act 1991 but has more limited scope for operation. The discretion under s 6D(b) to impose a disproportionate sentence need not be exercised where the number and gravity of offences provide sufficient scope for cumulation to achieve community protection through a proportionate sentence.
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