Khan, R. v [2025] EWCA Crim 1477 (29 October 2025)
The Recorder erred in law and procedure by imposing a compensation order without conducting a proper enquiry into the offender's means, without inviting submissions, and by awarding sums for aggravating features and delay, which are not permitted. The orders for compensation and costs were therefore quashed.
- Citation
- [2025] EWCA Crim 1477
- Parties
- Prosecution: Rex; Applicant: Raja Samil Khan
- Jurisdiction
- England and Wales
- Judgment Date
- 29 October 2025
- Procedural Posture
- Criminal Appeal / Appeal Against Sentence (compensation and Costs Orders)
- Outcome
- appeal allowed
- Legal Topics
- Compensation Orders, Costs Orders, Means Enquiry, Procedural Fairness, Sentencing Act 2020
Case Brief
Summary, issues, holding and outcome
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Parties
Rex
Prosecution
Raja Samil Khan
Applicant
Procedural Posture
Criminal Appeal / Appeal Against Sentence (compensation and Costs Orders)
Legal Issues
- 1 Whether the Crown Court erred in imposing a compensation order without proper enquiry into the offender's means
- 2 Whether the Recorder was entitled to award aggravated damages and interest for delay as part of a compensation order
- 3 Whether the costs order was properly imposed
Ratio Decidendi
The Recorder erred in law and procedure by imposing a compensation order without conducting a proper enquiry into the offender's means, without inviting submissions, and by awarding sums for aggravating features and delay, which are not permitted. The orders for compensation and costs were therefore quashed.
Court Disposition
appeal allowed
Orders
- compensation order quashed
- costs order quashed
Full Case Text
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