Williams, R. v [2025] EWCA Crim 955 (03 July 2025)

The judge erred by failing to apply the totality principle, as the breach and communication offences were different aspects of the same criminal conduct and should have attracted concurrent sentences. The total sentence should reflect the overall criminality, not simply aggregate individual sentences.

Citation: [2025] EWCA Crim 955
Parties: Prosecution: Rex; Appellant: Jack Williams
Jurisdiction: England and Wales
Judgment Date: 03 July 2025
Procedural Posture: Criminal Appeal / Appeal Against Sentence
Outcome: appeal allowed in part; sentence reduced
Legal Topics: Sentencing, Sexual Offences, Breach of Court Orders, Totality Principle

Criminal Law Sentencing Sexual Offences Breach of Court Orders Totality Principle

Case Brief

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Full judgment text Downloadable case file Legal principles 2 Authorities cited 2 Party arguments 2 Amounts and remedies 5

Parties

Rex

Prosecution

Jack Williams

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Sentence

Legal Issues

1 Whether the total sentence imposed was manifestly excessive
2 Whether the judge properly applied the totality principle in sentencing
3 Whether sentences for breach of Sexual Harm Prevention Order should have been concurrent with sentences for attempted sexual communication with a child

Ratio Decidendi

Court Disposition

appeal allowed in part; sentence reduced

Orders

Sentences on counts 5 and 6 increased to three years and six months each, to run concurrently with each other and all other sentences.
Total sentence reduced from five years to three years and six months' imprisonment.