Where an appellant had been convicted of a number of offences, in determining the appropriate custodial term under the Criminal Justice Act 2003 s.227 for the purpose of imposing an extended sentence the court should have passed concurrent extended sentences of sufficient length to reflect the totality of the offending, or at least a sentence in respect of one offence which fairly reflected the totality of the appellant's offending, and if that was of a length of four years or more extended that sentence.

CA (Crim Div) (Moore-Bick LJ, Irwin J) 3/11/2011
[2011] EWCA Crim 2790