Review of governing principles on when it is appropriate to stay a sentence that has been increased on appeal rather than reincarcerate the accused (with v. good dissent): R v Dufour, 2015 ONCA 426 at paras 11-29; R v HE, 2015 ONCA 531 at paras 56-57; R v Shi, 2015 ONCA 646 at para 13; see also e.g. in R v Huh, 2015 ONCA 356; see generally, R v Clouthier, 2016 ONCA 197 at para 63 

​Relevant factors include:

• the risk of distorting the sentencing process and the parity principle 

• the lenght of the sentence left to be served;

• rehabilitative steps taken by the offender, both before and after sentencing, and the degree to which those steps may be adversely affected by re-incarceration;

• the time that has elapsed from the imposition and completion of the sentences at trial

• responsibility for any delay in the appellate process;

• the potential for injustice if the sentence is served; and

• the seriousness of the offences in issue. 

Where the accused is being reincarcerated, time spent on parole can be counted towards time served: R v HE, 2015 ONCA 531 at para 61