Crewe, R. v [2025] EWCA Crim 741 (15 May 2025)

Crewe, R. v [2025] EWCA Crim 741 (15 May 2025)

The Recorder erred in reducing sentences for totality without principled justification and failed to ensure the sentence for controlling or coercive behaviour reflected the additional criminality of the concurrent offences. The aggregate sentence was unduly lenient and did not meet the requirement of proportionality for the seriousness of the offending.

Citation
[2025] EWCA Crim 741
Parties
Prosecutor: Rex; Offender: Jordan Crewe
Jurisdiction
England and Wales
Judgment Date
15 May 2025
Procedural Posture
Criminal Appeal (reference by Solicitor General Under S.36 Criminal Justice Act 1988) / Appeal Against Sentence; Review of Unduly Lenient Sentence
Outcome
Appeal allowed; sentence increased
Legal Topics
Sentencing, Totality Principle, Domestic Abuse, Harassment, Coercive and Controlling Behaviour, Assault Occasioning Actual Bodily Harm, Intentional Strangulation, Aggravating and Mitigating Factors

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Parties

Rex

Prosecutor

Jordan Crewe

Offender

Procedural Posture

Criminal Appeal (reference by Solicitor General Under S.36 Criminal Justice Act 1988) / Appeal Against Sentence; Review of Unduly Lenient Sentence

  1. 1 Whether the aggregate sentence imposed was unduly lenient
  2. 2 Whether the Recorder erred in applying the totality principle and in adjusting sentences for overlapping conduct
  3. 3 Whether aggravating and mitigating factors were properly balanced

Ratio Decidendi

The Recorder erred in reducing sentences for totality without principled justification and failed to ensure the sentence for controlling or coercive behaviour reflected the additional criminality of the concurrent offences. The aggregate sentence was unduly lenient and did not meet the requirement of proportionality for the seriousness of the offending.

Court Disposition

Appeal allowed; sentence increased

Orders

  • Sentence on first indictment quashed and substituted with seven months' imprisonment
  • Sentence on count 1 of second indictment quashed and substituted with 27 months' imprisonment