Reed, R. v [2025] EWCA Crim 1471 (29 October 2025)

Reed, R. v [2025] EWCA Crim 1471 (29 October 2025)

The extended sentence as originally imposed was unlawful because no single custodial term for a specified offence reached four years, as required by statute. The proper approach is to aggregate the offending into a single sentence for the lead offence, with all other sentences running concurrently, and to ensure the...

Source-derived case information.

Citation
[2025] EWCA Crim 1471
Parties
Respondent: Rex; Applicant: Adam Reed
Jurisdiction
England and Wales
Judgment Date
29 October 2025
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
appeal allowed in part
Legal Topics
Extended Sentences, Dangerous Offenders, Sentencing Guidelines, Totality Principle, Appeal Against Sentence
Criminal Law Extended Sentences Dangerous Offenders Sentencing Guidelines Totality Principle Appeal Against Sentence

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Parties

Rex

Respondent

Adam Reed

Applicant

Procedural Posture

Criminal Appeal / Appeal Against Sentence

Legal Issues

  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 under sentencing guidelines
  3. 3 Whether the overall sentence was manifestly excessive

Ratio Decidendi

The extended sentence as originally imposed was unlawful because no single custodial term for a specified offence reached four years, as required by statute. The proper approach is to aggregate the offending into a single sentence for the lead offence, with all other sentences running concurrently, and to ensure the total sentence is just and proportionate. The applicant is a dangerous offender and an extended sentence is appropriate, but the total custodial term should be five years with a two-year extended licence period.

Court Disposition

appeal allowed in part

Orders

  • Sentence of 27 months for assault occasioning actual bodily harm quashed and substituted with 18 months' imprisonment.
  • Sentence of three years nine months for false imprisonment quashed and substituted with five years' imprisonment.