Folkes, R v [2006] EWCA Crim 287 (19 January 2006)

Folkes, R v [2006] EWCA Crim 287 (19 January 2006)

The seriousness of the robbery offence did not justify a life sentence under section 225(2) Criminal Justice Act 2003; the appropriate sentence was imprisonment for public protection under section 225(3) due to the significant risk of serious harm to the public.

Citation
[2006] EWCA Crim 287
Parties
Prosecution: Regina; Applicant: Andre Folkes
Jurisdiction
England and Wales
Judgment Date
19 January 2006
Procedural Posture
Criminal Appeal / Application for Leave to Appeal Against Sentence, Renewed Before the Court of Appeal
Outcome
appeal allowed
Legal Topics
Robbery, Sentencing, Life Imprisonment, Imprisonment for Public Protection, Dangerous Offenders, Mental Health and Sentencing

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Parties

Regina

Prosecution

Andre Folkes

Applicant

Procedural Posture

Criminal Appeal / Application for Leave to Appeal Against Sentence, Renewed Before the Court of Appeal

  1. 1 Whether the sentence of life imprisonment under section 225(2) Criminal Justice Act 2003 was justified
  2. 2 Whether the seriousness of the offence justified a life sentence or a sentence of imprisonment for public protection

Ratio Decidendi

The seriousness of the robbery offence did not justify a life sentence under section 225(2) Criminal Justice Act 2003; the appropriate sentence was imprisonment for public protection under section 225(3) due to the significant risk of serious harm to the public.

Court Disposition

appeal allowed

Orders

  • Leave to appeal granted, limited to the question of sentence type
  • Life sentence set aside