Speed & Ors, R. v [2025] EWCA Crim 1582 (13 November 2025)

Speed & Ors, R. v [2025] EWCA Crim 1582 (13 November 2025)

The Court found no merit in Roseau's conviction appeal, holding that the direction regarding the agreed fact about the electricity supply did not render the conviction unsafe, as the issue was peripheral and the evidence against him was compelling. However, the Court held that in all three appellants' cases, the sentencing judge failed to make a sufficient or explicit adjustment for totality when imposing consecutive sentences for distinct offences. The aggregate sentences were therefore manifestly excessive and required modest downward adjustment to reflect the overall criminality.

Citation
[2025] EWCA Crim 1582
Parties
Prosecution: Rex; Appellant: Thomas Alan Speed; Appellant: Scott Fitzgerald Roseau; Appellant: James John Salkeld
Jurisdiction
England and Wales
Judgment Date
13 November 2025
Procedural Posture
Criminal Appeal / Court of Appeal Judgment on Conviction and Sentence
Outcome
Conviction appeal refused; sentence appeals allowed in part
Legal Topics
Conspiracy, Possession of Prohibited Weapons, Possession of Ammunition, Supply of Controlled Drugs, Sentencing, Totality Principle, Attribution of Evidence
Criminal Law Conspiracy Possession of Prohibited Weapons Possession of Ammunition Supply of Controlled Drugs Sentencing Totality Principle Attribution of Evidence

Case Brief

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Parties

Rex

Prosecution

Thomas Alan Speed

Appellant

Scott Fitzgerald Roseau

Appellant

James John Salkeld

Appellant

Procedural Posture

Criminal Appeal / Court of Appeal Judgment on Conviction and Sentence

Legal Issues

  1. 1 Whether the trial judge erred in directing the jury regarding agreed facts about the state of the property and electricity supply, impacting the safety of the conviction for Roseau
  2. 2 Whether the sentences imposed on Speed, Roseau, and Salkeld were manifestly excessive due to insufficient adjustment for totality

Ratio Decidendi

The Court found no merit in Roseau's conviction appeal, holding that the direction regarding the agreed fact about the electricity supply did not render the conviction unsafe, as the issue was peripheral and the evidence against him was compelling. However, the Court held that in all three appellants' cases, the sentencing judge failed to make a sufficient or explicit adjustment for totality when imposing consecutive sentences for distinct offences. The aggregate sentences were therefore manifestly excessive and required modest downward adjustment to reflect the overall criminality.

Court Disposition

Conviction appeal refused; sentence appeals allowed in part

Orders

  • Roseau's application for leave to appeal conviction refused; extension of time refused
  • Speed's sentence reduced from 28 to 26 years' imprisonment