Glover-Stuart, R. v [2025] EWCA Crim 1013 (01 July 2025)

Glover-Stuart, R. v [2025] EWCA Crim 1013 (01 July 2025)

The sentencing judge erred in failing to find abuse of trust, as the respondent created a situation where the victims were subject to his directions and relied on his representations, thus the offences should have been categorised as 3A with a higher starting point. The original sentence was unduly lenient and failed to reflect the seriousness of the offending.

Citation
[2025] EWCA Crim 1013
Parties
Prosecution: Rex; Respondent: Wayne Glover-Stuart
Jurisdiction
England and Wales
Judgment Date
01 July 2025
Procedural Posture
Criminal Appeal (attorney General's Reference) / Court of Appeal Judgment on Unduly Lenient Sentence Reference
Outcome
Appeal allowed; sentence increased
Legal Topics
Sentencing, Sexual Offences, Abuse of Trust, Appeal, Unduly Lenient Sentence
Criminal Law Sentencing Sexual Offences Abuse of Trust Appeal Unduly Lenient Sentence

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Parties

Rex

Prosecution

Wayne Glover-Stuart

Respondent

Procedural Posture

Criminal Appeal (attorney General's Reference) / Court of Appeal Judgment on Unduly Lenient Sentence Reference

Legal Issues

  1. 1 Whether the sentencing judge erred in categorising the offences as category 3B rather than 3A under the Sentencing Guidelines for causing a person to engage in sexual activity without consent
  2. 2 Whether there was an abuse of trust elevating culpability
  3. 3 Whether the original sentence was unduly lenient

Ratio Decidendi

The sentencing judge erred in failing to find abuse of trust, as the respondent created a situation where the victims were subject to his directions and relied on his representations, thus the offences should have been categorised as 3A with a higher starting point. The original sentence was unduly lenient and failed to reflect the seriousness of the offending.

Court Disposition

Appeal allowed; sentence increased

Orders

  • Original sentence quashed
  • Respondent sentenced to 3 years' imprisonment (2 years on count 2, 1 year consecutive on count 4)