Sentencing judges must always keep in mind the totality of the sentence imposed when dealing with multiple offences. They are under a duty to consider the fitness of the total sentence having regard to all the circumstances of the case. This requires an assessment of the impact of the sentence in relation to the seriousness of the conduct of the offender and its impact on the offender. One should also keep in mind the comment of Mr. Justice McQuaid in the Queen v. Edwards, [1986] 2 P.E.I.R. A1 at p. A1-4 that the application of the totality principle should not have the affect of reducing the end sentence to a term of less than what would be fit and appropriate for the most serious offence of the series of offences.
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