Khan, R. v [2025] EWCA Crim 1518 (06 November 2025)

Khan, R. v [2025] EWCA Crim 1518 (06 November 2025)

The judge was entitled to treat sexual communication with a child as the lead offence and to find significant harm based on victim impact statements, justifying Category 1 harm. However, the judge erred in categorising culpability as A rather than B, and the 20-year SHPO was excessive; a 10-year duration is appropriate.

Citation
[2025] EWCA Crim 1518
Parties
Prosecution: Rex; Appellant: Adnan Khan
Jurisdiction
England and Wales
Judgment Date
06 November 2025
Procedural Posture
Criminal Appeal / Court of Appeal Judgment
Outcome
Appeal allowed in part
Legal Topics
Harassment, Sexual Communication With a Child, Sentencing, Sexual Harm Prevention Order
Criminal Law Harassment Sexual Communication With a Child Sentencing Sexual Harm Prevention Order

Case Brief

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Parties

Rex

Prosecution

Adnan Khan

Appellant

Procedural Posture

Criminal Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the sentence imposed was manifestly excessive
  2. 2 Whether the categorisation of the offence as A1 was correct
  3. 3 Whether the Sexual Harm Prevention Order (SHPO) was necessary and its duration appropriate

Ratio Decidendi

The judge was entitled to treat sexual communication with a child as the lead offence and to find significant harm based on victim impact statements, justifying Category 1 harm. However, the judge erred in categorising culpability as A rather than B, and the 20-year SHPO was excessive; a 10-year duration is appropriate.

Court Disposition

Appeal allowed in part

Orders

  • SHPO duration reduced from 20 years to 10 years
  • Notification period under section 82 Sexual Offences Act 2003 set at 10 years