Manley, R. v [2025] EWCA Crim 1731 (09 December 2025)

Manley, R. v [2025] EWCA Crim 1731 (09 December 2025)

The original sentence was unduly lenient because it failed to properly categorise the offences under the guidelines, did not give sufficient weight to aggravating factors including racial motivation and previous convictions, and imposed a suspended sentence when only immediate custody was justified. The appropriate sentence, after full credit for guilty plea, was 2 years' immediate imprisonment for the principal offence, with concurrent sentences for the others.

Citation
[2025] EWCA Crim 1731
Parties
Prosecution: Rex; Respondent Offender: Nina Manley
Jurisdiction
England and Wales
Judgment Date
09 December 2025
Procedural Posture
Criminal Appeal (attorney General's Reference) / Appeal Against Sentence Under S.36 Criminal Justice Act 1988
Outcome
Appeal allowed; sentence increased
Legal Topics
Sentencing, Possession of Bladed Article, Threats to Kill, Racially Aggravated Offending, Mental Disorder in Sentencing
Criminal Law Sentencing Possession of Bladed Article Threats to Kill Racially Aggravated Offending Mental Disorder in Sentencing

Case Brief

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Parties

Rex

Prosecution

Nina Manley

Respondent Offender

Procedural Posture

Criminal Appeal (attorney General's Reference) / Appeal Against Sentence Under S.36 Criminal Justice Act 1988

Legal Issues

  1. 1 Whether the original sentence was unduly lenient
  2. 2 Proper categorisation under sentencing guidelines for possession of bladed articles and threats to kill
  3. 3 Appropriate weight to be given to mental disorder and previous convictions in sentencing

Ratio Decidendi

The original sentence was unduly lenient because it failed to properly categorise the offences under the guidelines, did not give sufficient weight to aggravating factors including racial motivation and previous convictions, and imposed a suspended sentence when only immediate custody was justified. The appropriate sentence, after full credit for guilty plea, was 2 years' immediate imprisonment for the principal offence, with concurrent sentences for the others.

Court Disposition

Appeal allowed; sentence increased

Orders

  • Original sentences quashed
  • 2 years' immediate imprisonment imposed for threatening to kill (principal offence)