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
Case Brief
Summary, issues, holding and outcome
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Parties
Adam Reed
Applicant
Rex
Respondent
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Legal Issues
- 1 Whether the imposition of an extended sentence was lawful under the Sentencing Code 2020
- 2 Whether the assault occasioning actual bodily harm was wrongly categorised resulting in an excessive starting point
- 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
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