R v Lloyd Sands

R v Lloyd Sands

The trial judge's directions on the use of evidence relating to the appellant's past behaviour were appropriate and fair, the judge correctly exercised her discretion under s.41 regarding cross-examination of the complainant, and the sentence imposed was not manifestly excessive given the aggravating features and harm suffered by the complainant.

Parties
Respondent: Rex; Appellant: Lloyd Sands
Jurisdiction
England and Wales
Judgment Date
20 January 2026
Procedural Posture
Criminal Appeal / Judgment on Appeal
Outcome
appeal dismissed
Legal Topics
Sexual Offences, Consent, Bad Character Evidence, Admissibility of Evidence, Sentencing, Cross Examination of Complainant, S.98 Criminal Justice Act 2003, S.41 Youth Justice and Criminal Evidence Act 1999
Criminal Law Sexual Offences Consent Bad Character Evidence Admissibility of Evidence Sentencing Cross Examination of Complainant S.98 Criminal Justice Act 2003 +1 more

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Parties

Rex

Respondent

Lloyd Sands

Appellant

Procedural Posture

Criminal Appeal / Judgment on Appeal

Legal Issues

  1. 1 Whether the trial judge failed to give proper directions on the use of evidence relating to the appellant's past behaviour under s.98 Criminal Justice Act 2003
  2. 2 Whether the trial judge erred in her ruling on the admissibility and scope of cross-examination about the complainant's sexual behaviour under s.41 Youth Justice and Criminal Evidence Act 1999
  3. 3 Whether the sentence imposed was manifestly excessive

Ratio Decidendi

The trial judge's directions on the use of evidence relating to the appellant's past behaviour were appropriate and fair, the judge correctly exercised her discretion under s.41 regarding cross-examination of the complainant, and the sentence imposed was not manifestly excessive given the aggravating features and harm suffered by the complainant.

Court Disposition

appeal dismissed

Orders

  • renewed application for leave to appeal against conviction under ground 5 refused
  • appeal against conviction dismissed