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Discretion to impose 


  • a trial judge’s decision to impose a consecutive versus a concurrent sentence is an exercise of his discretion that warrants a high degree of deference, absent an error in principle: R v Osman, 2016 ONCA 64 at para 8 



Consecutive Sentences


  • When the offences constitute invasions of different legally protected interests (e.g., dangerous/impaired driving and failing to stop at scene of an accident), consecutive sentences are generally warranted - subject to the principle of totality: R v Clouthier, 2016 ONCA 197 at para 55





  • A trial judge can impose consecutive sentences for robberies which occurred days and miles apart from each other: R v Hayes, 2016 ONCA 47 at para 7



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