Ratio Decidendi
The totality principle requires that when consecutive sentences are imposed, the overall sentence must be just and proportionate. The court should step back and consider whether the aggregate term is appropriate for the overall offending behaviour.
Fakty
The defendant was sentenced to consecutive terms of imprisonment for multiple offences, resulting in a long total sentence. He appealed on the ground of totality.
Podsumowanie orzeczenia
The Court of Appeal reduced the sentence, holding that while each individual sentence was appropriate, the totality was crushing and disproportionate. The court must consider whether concurrent or consecutive sentences are appropriate and ensure the total is just.
Kluczowe cytaty
"The court must step back and look at the total sentence and ask whether it is just and proportionate."
— Hooper LJ
Późniejsze zastosowanie
The totality principle is now codified in the Sentencing Council's Totality Guideline.