ANZ, R. v [2025] EWCA Crim 778 (09 July 2025)

ANZ, R. v [2025] EWCA Crim 778 (09 July 2025)

The sentencing judge failed to comply with the mandatory statutory requirement to have regard to the offender's means before imposing a compensation order, rendering the order unlawful and necessitating its quashing.

Citation
[2025] EWCA Crim 778
Parties
Respondent: Rex; Appellant: ANZ
Jurisdiction
England and Wales
Judgment Date
09 July 2025
Procedural Posture
Criminal Appeal / Appeal Against Sentence (compensation Order)
Outcome
Appeal allowed; compensation order quashed; no remission to Crown Court for reconsideration.
Legal Topics
Compensation Orders, Sentencing, Sexual Offences, Child Cruelty, Appeal Procedure
Criminal Law Compensation Orders Sentencing Sexual Offences Child Cruelty Appeal Procedure

Case Brief

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Parties

Rex

Respondent

ANZ

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Sentence (compensation Order)

Legal Issues

  1. 1 Whether the sentencing judge erred in law by imposing a compensation order without having regard to the offender's means as required by statute
  2. 2 Whether the compensation order of £10,000 was manifestly excessive and unlawful

Ratio Decidendi

The sentencing judge failed to comply with the mandatory statutory requirement to have regard to the offender's means before imposing a compensation order, rendering the order unlawful and necessitating its quashing.

Court Disposition

Appeal allowed; compensation order quashed; no remission to Crown Court for reconsideration.

Orders

  • Compensation Order of £10,000 set aside.
  • No further compensation order to be imposed.