Bukhari & Ors, R. v [2025] EWCA Crim 1353 (24 October 2025)

Bukhari & Ors, R. v [2025] EWCA Crim 1353 (24 October 2025)

The minimum term for Mahek Bukhari was excessive due to overvaluation of aggravating factors and undervaluation of youth and immaturity; the correct balance required a term below the statutory starting point. For manslaughter, the route to verdict may have been legally flawed for not identifying a base offence, warranting a full appeal. Sentences for manslaughter were manifestly excessive given minor roles and mitigation, requiring substantial reduction.

Citation
[2025] EWCA Crim 1353
Parties
Prosecution: Rex; Defendant/appellant: Mahek Bukhari; Defendant/appellant: Ameer Jamal; Defendant/appellant: Sanaf Gulammustafa; Defendant/appellant: Natasha Akhtar
Jurisdiction
England and Wales
Judgment Date
24 October 2025
Procedural Posture
Criminal Appeal / Court of Appeal (criminal Division) Judgment on Conviction and Sentence
Outcome
Appeals allowed in part; sentences quashed and substituted; leave to appeal against conviction granted on ground one for manslaughter appellants.
Legal Topics
Murder, Manslaughter, Joint Enterprise, Sentencing, Appeal Procedure
Criminal Law Murder Manslaughter Joint Enterprise Sentencing Appeal Procedure

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Parties

Rex

Prosecution

Mahek Bukhari

Defendant/appellant

Ameer Jamal

Defendant/appellant

Sanaf Gulammustafa

Defendant/appellant

Natasha Akhtar

Defendant/appellant

Procedural Posture

Criminal Appeal / Court of Appeal (criminal Division) Judgment on Conviction and Sentence

Legal Issues

  1. 1 Whether the minimum term for murder imposed on Mahek Bukhari was disproportionate and justified
  2. 2 Whether the convictions for manslaughter of Ameer Jamal, Sanaf Gulammustafa, and Natasha Akhtar were unsafe due to misdirection on the 'base offence' for unlawful act manslaughter
  3. 3 Whether the sentences for manslaughter were manifestly excessive

Ratio Decidendi

The minimum term for Mahek Bukhari was excessive due to overvaluation of aggravating factors and undervaluation of youth and immaturity; the correct balance required a term below the statutory starting point. For manslaughter, the route to verdict may have been legally flawed for not identifying a base offence, warranting a full appeal. Sentences for manslaughter were manifestly excessive given minor roles and mitigation, requiring substantial reduction.

Court Disposition

Appeals allowed in part; sentences quashed and substituted; leave to appeal against conviction granted on ground one for manslaughter appellants.

Orders

  • Minimum term for Mahek Bukhari quashed and substituted with 26 years and 285 days (after deductions).
  • Sentences for Ameer Jamal and Sanaf Gulammustafa quashed and substituted with 12 years 8 months and 12 years 9 months respectively (after curfew deductions).