Steele, R. v [2025] EWCA Crim 1467 (28 October 2025)
The aggregate sentence of 8 years for four rapes against a particularly vulnerable victim was unduly lenient; a significant uplift was required to reflect the seriousness and persistence of the conduct. The appropriate sentence is 12 years on count 1, with counts 2, 3, and 4 concurrent.
- Citation
- [2025] EWCA Crim 1467
- Parties
- Prosecution: Rex; Offender: Vernon Steele
- Jurisdiction
- England and Wales
- Judgment Date
- 28 October 2025
- Procedural Posture
- Criminal Appeal (reference by Attorney General Under S.36 Criminal Justice Act 1988) / Court of Appeal Judgment on Unduly Lenient Sentence Reference
- Outcome
- Sentence increased on Attorney General's reference
- Legal Topics
- Sentencing, Rape, Vulnerable Victims, Attorney General's Reference, Sexual Offences
Case Brief
Summary, issues, holding and outcome
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Parties
Rex
Prosecution
Vernon Steele
Offender
Procedural Posture
Criminal Appeal (reference by Attorney General Under S.36 Criminal Justice Act 1988) / Court of Appeal Judgment on Unduly Lenient Sentence Reference
Legal Issues
- 1 Whether the sentence imposed for four counts of rape was unduly lenient
- 2 Appropriate uplift for multiple offences against a vulnerable victim
Ratio Decidendi
The aggregate sentence of 8 years for four rapes against a particularly vulnerable victim was unduly lenient; a significant uplift was required to reflect the seriousness and persistence of the conduct. The appropriate sentence is 12 years on count 1, with counts 2, 3, and 4 concurrent.
Court Disposition
Sentence increased on Attorney General's reference
Orders
- Leave granted to refer sentence
- Sentence of 8 years on count 1 quashed
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