R v Adam Reed

R v Adam Reed

The extended sentence as originally imposed was unlawful because the four-year term condition was not met by a single sentence for a specified offence. The correct approach was to treat the false imprisonment as the lead offence, impose a five-year custodial term with a two-year extended licence, and run all other sentences concurrently, resulting in a total extended sentence of seven years. The original sentence was manifestly excessive and not just or proportionate to the offending as a whole.

Parties
Applicant: Adam Reed; Respondent: Rex
Jurisdiction
England and Wales
Judgment Date
29 January 2026
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
Appeal allowed in part; sentence varied
Legal Topics
Sentencing, Extended Sentences, Dangerous Offenders, Totality Principle, Assault Occasioning Actual Bodily Harm, False Imprisonment, Threats to Kill, Assault of Emergency Worker

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Parties

Adam Reed

Applicant

Rex

Respondent

Procedural Posture

Criminal Appeal / Appeal Against Sentence

  1. 1 Whether the imposition of an extended sentence was lawful under the Sentencing Code 2020
  2. 2 Whether the assault occasioning actual bodily harm was wrongly categorised resulting in an excessive starting point
  3. 3 Whether the overall sentence was manifestly excessive

Ratio Decidendi

The extended sentence as originally imposed was unlawful because the four-year term condition was not met by a single sentence for a specified offence. The correct approach was to treat the false imprisonment as the lead offence, impose a five-year custodial term with a two-year extended licence, and run all other sentences concurrently, resulting in a total extended sentence of seven years. The original sentence was manifestly excessive and not just or proportionate to the offending as a whole.

Court Disposition

Appeal allowed in part; sentence varied

Orders

  • Quash the sentence of 27 months for assault occasioning actual bodily harm and substitute 18 months' imprisonment
  • Quash the sentence of three years nine months for false imprisonment and substitute five years' imprisonment