R v Thomas Alan Speed & Ors
The court held that the trial judge's direction on the agreed fact regarding the electricity supply at the property did not render the conviction unsafe, as the issue was peripheral and did not materially affect the jury's assessment of the evidence. However, the court found that the sentencing judge failed to make a sufficient downward adjustment for totality when imposing consecutive sentences for firearms and drug offences. Accordingly, the sentences were quashed and substituted with reduced terms to reflect a modest adjustment for totality, resulting in lower aggregate sentences for each appellant.
- Parties
- Prosecution: Rex; Appellant: Thomas Alan Speed; Appellant: Scott Fitzgerald Roseau; Appellant: James John Salkeld
- Jurisdiction
- England and Wales
- Judgment Date
- 12 November 2025
- Procedural Posture
- Criminal Appeal / Judgment on Appeal Against Conviction and Sentence
- Outcome
- Appeals against sentence allowed; appeal against conviction refused; sentences quashed and substituted with reduced terms.
- Legal Topics
- Conspiracy, Possession of Prohibited Weapons, Possession of Ammunition, Supply of Controlled Drugs, Sentencing, Totality Principle, Attribution of Evidence
Case Brief
Summary, issues, holding and outcome
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Parties
Rex
Prosecution
Thomas Alan Speed
Appellant
Scott Fitzgerald Roseau
Appellant
James John Salkeld
Appellant
Procedural Posture
Criminal Appeal / Judgment on Appeal Against Conviction and Sentence
Legal Issues
- 1 Whether the trial judge erred in directing the jury on agreed facts regarding electricity at the property relevant to attribution of criminal conduct
- 2 Whether the sentences imposed were manifestly excessive due to insufficient adjustment for totality
Ratio Decidendi
The court held that the trial judge's direction on the agreed fact regarding the electricity supply at the property did not render the conviction unsafe, as the issue was peripheral and did not materially affect the jury's assessment of the evidence. However, the court found that the sentencing judge failed to make a sufficient downward adjustment for totality when imposing consecutive sentences for firearms and drug offences. Accordingly, the sentences were quashed and substituted with reduced terms to reflect a modest adjustment for totality, resulting in lower aggregate sentences for each appellant.
Court Disposition
Appeals against sentence allowed; appeal against conviction refused; sentences quashed and substituted with reduced terms.
Orders
- Mr Speed's sentence reduced from 28 years to 26 years' imprisonment.
- Mr Roseau's sentence reduced from 22 years to 20 years' imprisonment.
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