R v Mark Page

R v Mark Page

The sentence imposed was unduly lenient because the overall criminality, involving separate and distinct offences against different victims, was not adequately reflected by concurrent sentences. Consecutive sentences for Counts 4 and 5 were required to mark the seriousness and distinctness of the offences. The appropriate total sentence is 18 years' imprisonment.

Parties
Applicant: Her Majesty's Solicitor General; Offender/respondent: Mark Page
Jurisdiction
England and Wales
Judgment Date
10 June 2022
Procedural Posture
Criminal Appeal / Reference by Solicitor General Under S.36 Criminal Justice Act 1988 and Offender's Application for Leave to Appeal Against Sentence
Outcome
sentence increased on reference; offender's application for leave to appeal refused
Legal Topics
Sentencing, Sexual Offences, Child Exploitation, Appeals
Criminal Law Sentencing Sexual Offences Child Exploitation Appeals

Case Brief

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Parties

Her Majesty's Solicitor General

Applicant

Mark Page

Offender/respondent

Procedural Posture

Criminal Appeal / Reference by Solicitor General Under S.36 Criminal Justice Act 1988 and Offender's Application for Leave to Appeal Against Sentence

Legal Issues

  1. 1 Whether the sentence imposed on Mark Page was unduly lenient
  2. 2 Whether the judge erred in imposing concurrent rather than consecutive sentences
  3. 3 Whether the dangerousness provisions should have been considered

Ratio Decidendi

The sentence imposed was unduly lenient because the overall criminality, involving separate and distinct offences against different victims, was not adequately reflected by concurrent sentences. Consecutive sentences for Counts 4 and 5 were required to mark the seriousness and distinctness of the offences. The appropriate total sentence is 18 years' imprisonment.

Court Disposition

sentence increased on reference; offender's application for leave to appeal refused

Orders

  • Leave granted to Solicitor General to refer sentence as unduly lenient
  • Sentence on Counts 4 and 5 quashed and substituted with nine years' imprisonment each, to run concurrently with Counts 2 and 3 but consecutive to each other, total 18 years' imprisonment