Where an offender has completed a drug and alcohol treatment order for contemporaneous offending and there has been significant delay in charging and finalisation, the combination of the delay principle (R v Todd, endorsed in Mill v The Queen) and the totality principle may warrant fully suspended sentences even for serious offences of burglary, theft, and fraud. The totality principle extends beyond avoiding double punishment to recognise that the purposes of sentencing may be achieved at least to some extent by an earlier penalty, even for disparate offending.
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