R v BZG & Anor (A-G's Reference: child sex offences)

R v BZG & Anor (A-G's Reference: child sex offences)

Although the sentences were lenient and the categorisation of harm could have been higher, the judge's nuanced assessment of harm and culpability, particularly in ARY's case, was justified given the facts, vulnerabilities, and impact on the child. The court declined to interfere with the sentences, finding them calibrated to the highly unusual circumstances.

Parties
Applicant: The King; Respondent: BZG; Respondent: ARY
Jurisdiction
England and Wales
Judgment Date
05 September 2025
Procedural Posture
Criminal Appeal / Attorney General's Reference Under Section 36 Criminal Justice Act 1988; Appellate Judgment
Outcome
Leave to refer granted; sentences not altered
Legal Topics
Sentencing Guidelines, Unduly Lenient Sentences, Sexual Activity in Presence of Child, Causing/inciting Child to Engage in Sexual Activity, Mental Health Treatment Orders, Extended Sentences, Sexual Harm Prevention Orders
Criminal Law Child Protection Sexual Offences Sentencing Guidelines Unduly Lenient Sentences Sexual Activity in Presence of Child Causing/inciting Child to Engage in Sexual Activity Mental Health Treatment Orders +2 more

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Parties

The King

Applicant

BZG

Respondent

ARY

Respondent

Procedural Posture

Criminal Appeal / Attorney General's Reference Under Section 36 Criminal Justice Act 1988; Appellate Judgment

Legal Issues

  1. 1 Were the sentences imposed on BZG and ARY unduly lenient?
  2. 2 Were the offences correctly categorised under sentencing guidelines?
  3. 3 Did the judge give appropriate weight to aggravating and mitigating factors?

Ratio Decidendi

Although the sentences were lenient and the categorisation of harm could have been higher, the judge's nuanced assessment of harm and culpability, particularly in ARY's case, was justified given the facts, vulnerabilities, and impact on the child. The court declined to interfere with the sentences, finding them calibrated to the highly unusual circumstances.

Court Disposition

Leave to refer granted; sentences not altered

Orders

  • Leave to Attorney General to refer under section 36 Criminal Justice Act 1988
  • Sentences imposed by trial judge to stand