Tudor, R. v [2025] EWCA Crim 225 (21 February 2025)

Tudor, R. v [2025] EWCA Crim 225 (21 February 2025)

The sentencing judge was entitled to categorise the offence at the cusp between category B and C under the manslaughter guideline, make an upward adjustment for aggravating factors, and apply a 20% reduction for a guilty plea. The resulting sentence of 6 years' imprisonment was not unduly lenient as it fell within the reasonable range of judicial discretion.

Citation
[2025] EWCA Crim 225
Parties
Prosecution: Rex; Offender/respondent: Curtis Tudor
Jurisdiction
England and Wales
Judgment Date
21 February 2025
Procedural Posture
Criminal Appeal (attorney General's Reference) / Court of Appeal Judgment on Reference of Sentence Under S.36 Criminal Justice Act 1988
Outcome
application refused
Legal Topics
Manslaughter, Unduly Lenient Sentence, Attorney General's Reference, Sentencing Guidelines, Culpability Assessment
Criminal Law Sentencing Manslaughter Unduly Lenient Sentence Attorney General's Reference Sentencing Guidelines Culpability Assessment

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Parties

Rex

Prosecution

Curtis Tudor

Offender/respondent

Procedural Posture

Criminal Appeal (attorney General's Reference) / Court of Appeal Judgment on Reference of Sentence Under S.36 Criminal Justice Act 1988

Legal Issues

  1. 1 Whether the sentence imposed for manslaughter was unduly lenient under s.36 Criminal Justice Act 1988
  2. 2 Proper categorisation of culpability under the Sentencing Council's Unlawful Act Manslaughter Guideline
  3. 3 Appropriate adjustment for aggravating and mitigating factors in sentencing

Ratio Decidendi

The sentencing judge was entitled to categorise the offence at the cusp between category B and C under the manslaughter guideline, make an upward adjustment for aggravating factors, and apply a 20% reduction for a guilty plea. The resulting sentence of 6 years' imprisonment was not unduly lenient as it fell within the reasonable range of judicial discretion.

Court Disposition

application refused

Orders

  • Application by the Solicitor General under s.36 Criminal Justice Act 1988 refused.