The totality principle has very limited application in moderating sentences for serious offences committed in the prison environment, particularly where the offending is motivated by vigilantism, the offender has poor rehabilitation prospects, and the need for general and personal deterrence is high. A 25% totality reduction from a notional starting point of 12 years was held to be manifestly inadequate for a premeditated attempted murder involving 47 stab wounds committed in prison. Sentences for attempted murder in Western Australia have no established tariff or sentencing range.
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