R v Liam Haslam

R v Liam Haslam

The increase in maximum sentence to life imprisonment under the 2022 Act was intended for the most serious (level 1) cases and does not justify increasing sentences for level 2 and 3 offences pending a revised Sentencing Council Guideline. The sentencing judge erred in categorising the offence as level 3; it was properly level 2. However, the sentence, though lenient, was not unduly lenient and does not warrant appellate intervention.

Parties
Applicant: His Majesty's Solicitor General; Respondent: Liam Haslam
Jurisdiction
England and Wales
Judgment Date
11 September 2024
Procedural Posture
Criminal Appeal (reference by Attorney General) / Application for Leave and Substantive Hearing
Outcome
reference dismissed
Legal Topics
Causing Death by Dangerous Driving, Sentencing Guidelines, Unduly Lenient Sentence, Effect of Statutory Maximum Increase
Criminal Law Sentencing Causing Death by Dangerous Driving Sentencing Guidelines Unduly Lenient Sentence Effect of Statutory Maximum Increase

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Parties

His Majesty's Solicitor General

Applicant

Liam Haslam

Respondent

Procedural Posture

Criminal Appeal (reference by Attorney General) / Application for Leave and Substantive Hearing

Legal Issues

  1. 1 Whether the increase in maximum sentence for causing death by dangerous driving under the Police, Crime, Sentencing and Courts Act 2022 should affect sentences for level 2 and 3 offending under the Sentencing Council Guideline
  2. 2 Whether the sentencing judge was correct to categorise the offence as high level 3 rather than level 2
  3. 3 Whether the sentence imposed was unduly lenient

Ratio Decidendi

The increase in maximum sentence to life imprisonment under the 2022 Act was intended for the most serious (level 1) cases and does not justify increasing sentences for level 2 and 3 offences pending a revised Sentencing Council Guideline. The sentencing judge erred in categorising the offence as level 3; it was properly level 2. However, the sentence, though lenient, was not unduly lenient and does not warrant appellate intervention.

Court Disposition

reference dismissed

Orders

  • Leave to refer granted
  • Reference dismissed; sentence not increased