Patel, R. v [2026] EWCA Crim 246 (12 February 2026)

Patel, R. v [2026] EWCA Crim 246 (12 February 2026)

The original sentence of 9 years was unduly lenient given the frequency and persistence of the rapes, the profound and ongoing harm caused to the victim, and the additional criminality of indecent assaults. The proper sentence, reflecting the near-campaign nature of the offending and the severe consequences, is 16 years' imprisonment concurrent on the principal counts.

Citation
[2026] EWCA Crim 246
Parties
Appellant: Rex; Respondent: Kishor Patel
Jurisdiction
England and Wales
Judgment Date
12 February 2026
Procedural Posture
Criminal Appeal (reference by Attorney General Under S.36 Criminal Justice Act 1988) / Court of Appeal Judgment on Sentence
Outcome
appeal allowed; sentence increased
Legal Topics
Rape, Indecent Assault, Sentencing, Unduly Lenient Sentence, Attorney General's Reference
Criminal Law Rape Indecent Assault Sentencing Unduly Lenient Sentence Attorney General's Reference

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Parties

Rex

Appellant

Kishor Patel

Respondent

Procedural Posture

Criminal Appeal (reference by Attorney General Under S.36 Criminal Justice Act 1988) / Court of Appeal Judgment on Sentence

Legal Issues

  1. 1 Whether the original sentence for multiple counts of rape and indecent assault was unduly lenient
  2. 2 Proper categorisation of offences under sentencing guidelines
  3. 3 Appropriate sentence for campaign-like sexual offending against a child

Ratio Decidendi

The original sentence of 9 years was unduly lenient given the frequency and persistence of the rapes, the profound and ongoing harm caused to the victim, and the additional criminality of indecent assaults. The proper sentence, reflecting the near-campaign nature of the offending and the severe consequences, is 16 years' imprisonment concurrent on the principal counts.

Court Disposition

appeal allowed; sentence increased

Orders

  • Sentences of 9 years on counts 4 and 7 quashed and substituted with sentences of 16 years on each count, concurrent with other sentences.