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
Case Brief
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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
Legal Issues
- 1 Whether the aggregate sentence imposed was unduly lenient
- 2 Whether the Recorder erred in applying the totality principle and in adjusting sentences for overlapping conduct
- 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
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