Salem & Anor, R. v [2025] EWCA Crim 1602 (19 December 2025)

Salem & Anor, R. v [2025] EWCA Crim 1602 (19 December 2025)

The Crown Court was properly vested with unlimited sentencing powers as the matter was committed for both confiscation and sentence; the fines and costs imposed were not manifestly excessive given the appellants' culpability, benefit, and conduct; costs orders were justified as the appellants' actions caused unnecessary expense and delay; findings in confiscation proceedings did not bind the sentencing judge where further evidence of means was available.

Citation
[2025] EWCA Crim 1602
Parties
Prosecution: Rex; Appellant: Joel Salem; Appellant: Judith Veronique Robinson-Dadoun
Jurisdiction
England and Wales
Judgment Date
19 December 2025
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
appeal dismissed
Legal Topics
Sentencing Powers, Proceeds of Crime, Enforcement Notice, Costs Orders, Confiscation Proceedings
Criminal Law Planning Law Sentencing Powers Proceeds of Crime Enforcement Notice Costs Orders Confiscation Proceedings

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Parties

Rex

Prosecution

Joel Salem

Appellant

Judith Veronique Robinson-Dadoun

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Sentence

Legal Issues

  1. 1 Whether the Crown Court's sentencing powers were limited to those of the Magistrates' Court for part of the offending period
  2. 2 Whether the fines and costs imposed were manifestly excessive
  3. 3 Whether the judge erred in awarding prosecution costs for both prosecution and confiscation proceedings

Ratio Decidendi

The Crown Court was properly vested with unlimited sentencing powers as the matter was committed for both confiscation and sentence; the fines and costs imposed were not manifestly excessive given the appellants' culpability, benefit, and conduct; costs orders were justified as the appellants' actions caused unnecessary expense and delay; findings in confiscation proceedings did not bind the sentencing judge where further evidence of means was available.

Court Disposition

appeal dismissed

Orders

  • Fines and costs orders against both appellants remain undisturbed.