R v Samuel Liam Dixon

R v Samuel Liam Dixon

The sentencing judge was under a statutory obligation to specify the number of days spent on qualifying curfew to be credited against the activated sentence. The failure to do so was an error. The Court of Appeal rectified this by certifying 61 days to be credited, while adjusting the sentence to avoid double counting, resulting in a neutral effect on the total sentence.

Parties
Prosecutor: Rex; Appellant: Samuel Liam Dixon
Jurisdiction
England and Wales
Judgment Date
01 May 2026
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Sentence
Outcome
Appeal allowed to the extent of correcting the sentence and certifying curfew credit.
Legal Topics
Sentencing Procedure, Qualifying Curfew Credit, Suspended Sentence Activation, Time Served Calculation
Criminal Law Sentencing Sentencing Procedure Qualifying Curfew Credit Suspended Sentence Activation Time Served Calculation

Case Brief

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Parties

Rex

Prosecutor

Samuel Liam Dixon

Appellant

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Sentence

Legal Issues

  1. 1 Whether the sentencing judge erred in failing to certify the number of days spent on qualifying curfew to be credited against the activated sentence
  2. 2 Whether the appellant is entitled to credit for time spent on qualifying curfew under section 325 of the Sentencing Act 2020
  3. 3 Whether the sentence should be adjusted to avoid double counting of curfew credit

Ratio Decidendi

The sentencing judge was under a statutory obligation to specify the number of days spent on qualifying curfew to be credited against the activated sentence. The failure to do so was an error. The Court of Appeal rectified this by certifying 61 days to be credited, while adjusting the sentence to avoid double counting, resulting in a neutral effect on the total sentence.

Court Disposition

Appeal allowed to the extent of correcting the sentence and certifying curfew credit.

Orders

  • The two activated sentences from the 2024 suspended sentence order are increased from seven months each consecutive to eight months each consecutive.
  • The total sentence is revised to 20 months' imprisonment.