Croft, R. v [2025] EWCA Crim 1609 (11 November 2025)

Croft, R. v [2025] EWCA Crim 1609 (11 November 2025)

The sentencing judge erred by not making a further downwards adjustment after imposing consecutive sentences for two sets of similar drug offences, resulting in a manifestly excessive sentence. The appropriate application of the Totality Principle required a reduction to ensure the sentence was just and proportionate.

Source-derived case information.

Citation
[2025] EWCA Crim 1609
Parties
Prosecution: Rex; Appellant: Alan Anthony Croft
Jurisdiction
England and Wales
Judgment Date
11 November 2025
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
appeal allowed in part
Legal Topics
Sentencing, Drug Offences, Totality Principle, Appeal Against Sentence
Criminal Law Sentencing Drug Offences Totality Principle Appeal Against Sentence

Source-derived case record

Summary, issues, holding and outcome

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Parties

Rex

Prosecution

Alan Anthony Croft

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Sentence

Legal Issues

  1. 1 Whether the sentencing judge properly applied the Totality Principle when imposing consecutive sentences for drug offences
  2. 2 Whether the overall sentence was manifestly excessive

Ratio Decidendi

The sentencing judge erred by not making a further downwards adjustment after imposing consecutive sentences for two sets of similar drug offences, resulting in a manifestly excessive sentence. The appropriate application of the Totality Principle required a reduction to ensure the sentence was just and proportionate.

Court Disposition

appeal allowed in part

Orders

  • Sentences of 4 years 6 months under counts 1 and 2 of October offending quashed and substituted with 3 years concurrent on each (4 years before discount for plea)
  • Total sentence reduced to 6 years 4 months imprisonment