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England and Wales decisions
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The sentencing judge properly exercised discretion, considered the correct guideline, and balanced the relevant factors. The seriousness of repeated domestic abuse justified immediate custody, and the decision not to suspend was not unreasonable.
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Wheatley-Taylor, R. v [2026] EWCA Crim 446 (31 March 2026)
The Court of Appeal held that the sentencing judge erred in refusing to find dangerousness in a domestic abuse arson case and substituted an extended sentence.
The original sentence was unduly lenient given the seriousness, persistence, and aggravating features of the offending; immediate custodial sentences were required for each count, with credit for the guilty plea reducing the term to 34 months' imprisonment per count, to run concurrently.
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The seriousness, persistence, and violence of the offending, including repeated intentional strangulation and coercive control, required an immediate custodial sentence; the original community order was unduly lenient and outside the sentencing range.
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Thornton, R. v [2025] EWCA Crim 1845 (16 December 2025)
The Court of Appeal Criminal Division increased a domestic abuse sentence after finding a community order unduly lenient for coercive control and two strangulation counts.
Thornton, R. v [2025] EWCA Crim 1734 (16 December 2025)
The Court of Appeal increased a community sentence for coercive control and two strangulation offences to concurrent 34-month prison terms.
The overall sentence of three-and-a-half years for both offences, considering aggravating factors and the seriousness of the conduct, was not excessive and fell within the guideline range.
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The sentence was not manifestly excessive; the judge properly assessed dangerousness and delay, and the extended sentence was justified given the seriousness and applicant's lack of remorse.
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Hamad, R. v [2025] EWCA Crim 1503 (30 October 2025)
The Court of Appeal Criminal Division refused leave to appeal against a 12-year extended sentence for assault by penetration and intentional strangulation.
The judge properly considered all relevant factors and guidelines; the refusal to suspend the sentence was within reasonable judicial discretion and did not result in an excessive sentence.
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