Hall, R. v [2025] EWCA Crim 1605 (21 November 2025)

Hall, R. v [2025] EWCA Crim 1605 (21 November 2025)

The appellant's conduct should have been placed in culpability category 2B, not 2A, given his lack of prior knowledge, limited role, and actions in excessive self-defence. The appropriate sentence before credit for plea was 18 months, reduced to 16 months with credit. However, the seriousness of the offence required immediate custody and did not justify suspension of the sentence.

Citation
[2025] EWCA Crim 1605
Parties
Prosecution: R; Appellant: Mark Anthony Hall
Jurisdiction
England and Wales
Judgment Date
21 November 2025
Procedural Posture
Criminal Appeal / Appeal Against Sentence
Outcome
appeal allowed in part
Legal Topics
Violent Disorder, Sentencing, Joint Enterprise, Public Order Act 1986, Appeal Against Sentence
Criminal Law Violent Disorder Sentencing Joint Enterprise Public Order Act 1986 Appeal Against Sentence

Case Brief

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Parties

R

Prosecution

Mark Anthony Hall

Appellant

Procedural Posture

Criminal Appeal / Appeal Against Sentence

Legal Issues

  1. 1 Whether the sentence imposed for violent disorder was manifestly excessive
  2. 2 Whether the appellant's conduct was properly categorised as category 2A or 2B under sentencing guidelines
  3. 3 Whether the sentence should have been suspended

Ratio Decidendi

The appellant's conduct should have been placed in culpability category 2B, not 2A, given his lack of prior knowledge, limited role, and actions in excessive self-defence. The appropriate sentence before credit for plea was 18 months, reduced to 16 months with credit. However, the seriousness of the offence required immediate custody and did not justify suspension of the sentence.

Court Disposition

appeal allowed in part

Orders

  • Sentence of imprisonment reduced from 22 months to 16 months
  • Application for suspension of sentence refused