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

Examples

• 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