R v Steven Sillitto

The Recorder erred in principle by imposing an indefinite sentence rather than an extended sentence, failing to sufficiently assess the future risk and the protective effect of ancillary orders. An extended sentence with a suitably drafted SOPO would have provided appropriate protection to the public.

Source-derived case information.

Parties: Appellant: Steven Sillitto; Respondent: R
Jurisdiction: England and Wales
Judgment Date: 07 September 2025
Procedural Posture: Criminal Appeal / Judgment on Appeal Against Sentence
Outcome: appeal allowed in part
Legal Topics: Sentencing, Sexual Offences, Dangerous Offenders, Extended Sentences, Sexual Offences Prevention Orders

Criminal Law Sentencing Sexual Offences Dangerous Offenders Extended Sentences Sexual Offences Prevention Orders

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Full judgment text Downloadable case file Legal principles 2 Authorities cited 8 Party arguments 2 Amounts and remedies 5

Parties

Steven Sillitto

Appellant

Respondent

Procedural Posture

Criminal Appeal / Judgment on Appeal Against Sentence

Legal Issues

1 Whether the indefinite sentence of detention for public protection was wrong in principle or manifestly excessive
2 Whether an extended sentence with ancillary orders would have provided sufficient protection to the public

Ratio Decidendi

Court Disposition

appeal allowed in part

Orders

Indefinite sentence on Count 1 quashed and replaced with an extended sentence of 9 years (6 years custodial, 3 years extended licence) under section 227 Criminal Justice Act 2003.
Original SOPO quashed and replaced with a time-limited SOPO with additional prohibitions, running until 17 June 2035.

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