R v Steven Carl Evans

R v Steven Carl Evans

The custodial period of 24 years was unduly lenient given the gravity and multiplicity of the offences. A custodial period of at least 30 years was required to reflect the overall seriousness, but a life sentence was not mandatory as the judge was entitled to conclude it was not necessary as a last resort. The extended sentence structure was appropriate, but the custodial term was increased to 30 years.

Parties
Applicant: His Majesty’s Solicitor General; Respondent/offender: Steven Carl Evans
Jurisdiction
England and Wales
Judgment Date
14 November 2024
Procedural Posture
Criminal Appeal (reference by Attorney General) / Sentence Review Under Section 36 Criminal Justice Act 1988
Outcome
Sentence increased on reference; custodial term substituted
Legal Topics
Sentencing, Sexual Offences, Appeal, Unduly Lenient Sentences
Criminal Law Sentencing Sexual Offences Appeal Unduly Lenient Sentences

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Parties

His Majesty’s Solicitor General

Applicant

Steven Carl Evans

Respondent/offender

Procedural Posture

Criminal Appeal (reference by Attorney General) / Sentence Review Under Section 36 Criminal Justice Act 1988

Legal Issues

  1. 1 Whether the sentence imposed was unduly lenient
  2. 2 Whether a life sentence was required under section 285 of the Sentencing Code
  3. 3 Appropriateness of concurrent sentences for multiple sexual offences

Ratio Decidendi

The custodial period of 24 years was unduly lenient given the gravity and multiplicity of the offences. A custodial period of at least 30 years was required to reflect the overall seriousness, but a life sentence was not mandatory as the judge was entitled to conclude it was not necessary as a last resort. The extended sentence structure was appropriate, but the custodial term was increased to 30 years.

Court Disposition

Sentence increased on reference; custodial term substituted

Orders

  • Custodial period increased to 30 years’ imprisonment on count 30
  • Extended licence period of 8 years maintained