Blight, R. v

Blight, R. v

The proper measure of loss for sentencing in fraud involving failure to disclose wreck is the full value of the property withheld, as the offenders were not entitled to any salvage award or deduction. The sentences imposed were appropriate except for the need to adjust the distribution of sentences across counts for...

Source-derived case information.

Parties
Appellant: John Simon Blight; Appellant: Nigel Ingram; Respondent: Regina
Jurisdiction
England and Wales
Judgment Date
12 February 2019
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Sentence
Outcome
appeals dismissed save for variation of sentences on counts 1, 2, and 4 for Mr Ingram
Legal Topics
Fraud, Sentencing, Failure to Disclose Wreck, Assessment of Harm, Salvage Rights
Criminal Law Maritime Law Fraud Sentencing Failure to Disclose Wreck Assessment of Harm Salvage Rights

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Summary, issues, holding and outcome

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Parties

John Simon Blight

Appellant

Nigel Ingram

Appellant

Regina

Respondent

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Sentence

Legal Issues

  1. 1 Proper approach to sentencing for fraud involving failure to disclose wreck
  2. 2 Assessment of harm for sentencing purposes in wreck-related fraud
  3. 3 Entitlement to salvage awards for offenders acting outside the law

Ratio Decidendi

The proper measure of loss for sentencing in fraud involving failure to disclose wreck is the full value of the property withheld, as the offenders were not entitled to any salvage award or deduction. The sentences imposed were appropriate except for the need to adjust the distribution of sentences across counts for Mr Ingram, without altering the total sentence.

Court Disposition

appeals dismissed save for variation of sentences on counts 1, 2, and 4 for Mr Ingram

Orders

  • Sentence on count 1 for Mr Ingram increased to 4 years' imprisonment
  • Sentences on counts 2 and 4 for Mr Ingram reduced to 18 months each, all sentences concurrent