Totality
In cases of multiple offences, the Court needs to look at the totality of the criminal behaviour to determine what is an appropriate sentence.
Reflected in the Penalties and Sentences Act (Qld) 1992 at s9(2)(k-n).
Mill (1998) 166 CLR 59 at 63: “The effect of the totality principle is to require a sentencer…to review the aggregate sentence and consider whether …[its] ‘just and appropriate.’”
A Court can reflect totality principle by (R v Nagy [2004] 1 Qd R 63):-
▫Imposing a head sentence for the most serious offence, reflecting the totality of the criminal behaviour (more than it would have been alone), together with concurrent lesser sentences. (But note the restrictions on this method if it would push the sentence into the realm where Serious Violent Offence declarations must be made).
▫Reducing sentences but making them cumulative.