• The totality principle requires that a combined sentence must not be unduly long or harsh in the sense that its impact simply exceeds the gravity of the offences in question or the overall culpability of the offender: R v Johnson, 2012 ONCA 39 at paras 15-18



Totality Principle and Consecutive Sentences


  • The totality principle applies where:

  1. a single judge must deal with a series of offences, some of which require the imposition of consecutive sentences having regard to the criteria for such sentences.

  2. a sentencing judge must impose a fit sentence on an offender convicted of one or more offences where that offender is at the same time serving the remainder of a sentence for a previous conviction or convictions.

    • the subsequent sentencing judge will determine how much weight to give to the existing remaining sentence by assessing whether the length of the proposed sentence plus the existing sentence will result in a “just and appropriate” disposition that reflects as aptly as possible the relevant principles and goals of sentencing in the circumstances: R v Johnson, 2012 ONCA 39