March, R. v [2026] EWCA Crim 481 (26 March 2026)

March, R. v [2026] EWCA Crim 481 (26 March 2026)

The case fell within Schedule 21, Paragraph 2(2)(e) as a murder by an offender previously convicted of murder, making a whole life order the starting point. The aggravating factors, including coercive control, the presence and harm to a child, and the death of an unborn child, substantially outweighed limited mitigation. The judge erred in structure and in giving weight to the guilty plea; the sentence was unduly lenient and a whole life order was required.

Citation
[2026] EWCA Crim 481
Parties
Prosecution: Rex; Respondent Offender/applicant: Shaine March
Jurisdiction
England and Wales
Judgment Date
26 March 2026
Procedural Posture
Criminal Appeal and Attorney General Reference / Court of Appeal Judgment on Sentence Review and Application for Leave to Appeal
Outcome
Appeal by offender refused; Attorney General's reference allowed; sentence quashed and replaced with whole life order.
Legal Topics
Sentencing, Murder, Whole Life Order, Unduly Lenient Sentence, Manifestly Excessive Sentence, Aggravating and Mitigating Factors
Criminal Law Sentencing Murder Whole Life Order Unduly Lenient Sentence Manifestly Excessive Sentence Aggravating and Mitigating Factors

Case Brief

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Parties

Rex

Prosecution

Shaine March

Respondent Offender/applicant

Procedural Posture

Criminal Appeal and Attorney General Reference / Court of Appeal Judgment on Sentence Review and Application for Leave to Appeal

Legal Issues

  1. 1 Whether the sentence imposed for murder was unduly lenient and should have been a whole life order under Schedule 21 of the Sentencing Act 2020
  2. 2 Whether the minimum term of 42 years was manifestly excessive or wrong in principle

Ratio Decidendi

The case fell within Schedule 21, Paragraph 2(2)(e) as a murder by an offender previously convicted of murder, making a whole life order the starting point. The aggravating factors, including coercive control, the presence and harm to a child, and the death of an unborn child, substantially outweighed limited mitigation. The judge erred in structure and in giving weight to the guilty plea; the sentence was unduly lenient and a whole life order was required.

Court Disposition

Appeal by offender refused; Attorney General's reference allowed; sentence quashed and replaced with whole life order.

Orders

  • Leave to appeal against sentence refused for Shaine March.
  • Leave to refer sentence as unduly lenient granted to Solicitor General.