{"id":658868,"date":"2026-04-23T12:22:25","date_gmt":"2026-04-23T10:22:25","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/rex-v-mark-anthony-wilson\/"},"modified":"2026-04-23T12:22:25","modified_gmt":"2026-04-23T10:22:25","slug":"rex-v-mark-anthony-wilson","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ru\/jurisprudences\/rex-v-mark-anthony-wilson\/","title":{"rendered":"REX v MARK ANTHONY WILSON"},"content":{"rendered":"
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LORD JUSTICE SINGH: Introduction 1 This is an application on behalf of His\u00a0Majesty's Solicitor General for permission to refer a\u00a0sentence to this court on the ground that it was unduly lenient under s.36 of the\u00a0Criminal Justice Act 1988 ("the\u00a01988 Act"). 2 The\u00a0principles to be applied on such application are well established and have been summarised as follows: (1) The\u00a0judge at first instance is particularly well placed to assess the\u00a0weight to be given to competing factors in considering sentence. (2) A\u00a0sentence is only unduly lenient where it falls outside the\u00a0range of sentences which the\u00a0judge at first instance might reasonably consider appropriate. (3) Leave to refer a\u00a0sentence should only be granted by this court in exceptional circumstances and not in borderline cases. (4) Section 36 of the 1988 Act is designed to deal with cases where judges have fallen into gross error: see, for example, Attorney General's Reference (Azad) [2021] EWCA Crim 1846, [2022] 2 Crim App R (S) 10 at para.72 in a\u00a0judgment given by the Chancellor of the High Court. 3 The\u00a0respondent offender in the\u00a0present case was sentenced for a\u00a0large number of offences to which he had pleaded guilty in the\u00a0Magistrates' Court. There were 27 charges in all. On committal for sentence, he was sentenced by HHJ\u00a0Stead at the Crown Court at Teesside on 15\u00a0June\u00a02022 to a\u00a0total of six years and eight\u00a0months' imprisonment. The\u00a0charges against the offender had been brought in three tranches. The\u00a0first ten charges formed the\u00a0basis of committal S20210372. He entered guilty pleas at York Magistrates' Court on 22\u00a0June\u00a02021. The\u00a0five charges which formed the\u00a0basis of committal S20210349 were the\u00a0subject of pleas on 16\u00a0August\u00a02021 at the same court. The\u00a012 charges that were the\u00a0basis of committal S20220034 were the subject of guilty pleas at the same court on 3\u00a0February\u00a02022. 4 In brief, the\u00a0charges related to the\u00a0offender communicating with, predominantly children, using various social media applications. He demanded indecent images of some of the children and, on occasion, threatened them with publication of this material if they did not send him further images. The\u00a0facts are set out in detail at para.9 to 54 of the final reference before this court, but it is unnecessary for present purposes to rehearse the\u00a0details here. It should be noted, however, that there were a\u00a0large number of offences affecting many victims, including ten named victims, as well as others who clearly could not be identified because of the nature of the image offences. The\u00a0offending spanned a\u00a0period of some four years between 2017 and 2021. There were also disturbing elements of coercion and the\u00a0making of threats that the offender would disclose to the children's parents what they had been doing on social media. On one occasion, the\u00a0offender pretended to be a\u00a010-year-old girl himself. We also note that some of the offences under committal S20220024 were committed while he had been released by the police pending investigation of earlier offences. The Sentencing Process 5 The\u00a0offender was born on 15\u00a0September\u00a01986 and was aged 35. He had no previous convictions. The\u00a0sentencing judge had several reports before him. These included a\u00a0psychiatric report prepared by Dr James Todd on 18\u00a0October\u00a02021. This said that the offender has a\u00a0longstanding diagnosis of Autistic Spectrum Disorder. He was himself exposed to sexual abuse at an\u00a0early age. The report concluded that the offender's experiences had resulted in behavioural problems that could be described as Attachment Disorder and Conduct Disorder. A\u00a0later second report was obtained, but this was not served because it did not support the\u00a0recommendation that there should be a\u00a0Hospital Order made under s.37 of the Mental Health Act 1983. 6 The\u00a0judge also had a\u00a0pre-sentence report prepared on 6\u00a0September\u00a02021 and an\u00a0addendum to that report of 1\u00a0April\u00a02022. The\u00a0report expressed concern about the offender's behaviour, in particular because his offending had occurred over a\u00a0long period between 2017 and 2021 and the\u00a0offender sought to belittle his motivations. There was according to the\u00a0report a "clearly established behaviour linked to sexual offending and\u00a0threatening behaviour via electronic communication all linked to children". The\u00a0offender was assessed in the\u00a0report as posing a\u00a0high risk of re-offending. He was found to pose a\u00a0medium risk of committing a serious further offence in the\u00a0next two years. He was assessed as a\u00a0high risk of serious harm to children. In the\u00a0addendum report, the view was expressed that his behaviour was unlikely to change. 7 The\u00a0judge also had, and we have seen, victim personal statements from two of the victims. They spoke to the\u00a0continued impact on both victims of the offender's conduct. 8 The\u00a0numerous offences in this case fell into the\u00a0following categories: (1) Causing or inciting a\u00a0child under 13 to engage in sexual activity (non-penetrative) for which the\u00a0maximum penalty is 14\u00a0years' imprisonment. There were two charges of this kind. (2) Causing or inciting a\u00a0child aged 13 to 15 to engage in sexual activity (non-penetrative) for which the\u00a0maximum penalty is again 14\u00a0years' imprisonment. There was one charge of this kind. (3) Distributing or making indecent images of children for which the maximum penalty is 10\u00a0years' imprisonment. There were 14 charges of this kind. (4) Sending an electronic communication which was grossly offensive for which the maximum penalty was two\u00a0years' imprisonment. There were four charges of this type. (5) Disclosing a\u00a0private photograph without the consent of an\u00a0individual with the intention of causing that individual distress for which the maximum penalty is two\u00a0years' imprisonment. There was one charge of this type. (6) Engaging in sexual communications with a\u00a0child for which the maximum penalty is two\u00a0years' imprisonment. There were five charges of this type. 9 There are relevant sentencing guidelines in relation to some but not all of those offences. The\u00a0judge had the\u00a0benefit of a\u00a0detailed sentencing note on behalf of the\u00a0prosecution. He also had submissions on behalf of the prosecution and in mitigation on behalf of the\u00a0offender. To some extent, criticism is now made of the way in which the case was presented before the judge by counsel for the prosecution, although, in fairness, that has not been at the heart of the submissions made on behalf of the\u00a0Solicitor General. 10 In arriving at sentence, the\u00a0judge selected as the\u00a0two most serious offences the\u00a0charges of causing or inciting a child under 13 to engage in sexual activity (non-penetrative) contrary to s.8 of the Sexual Offences Act 2003. He imposed a\u00a0sentence of four years' imprisonment on those two charges concurrent to each other, but consecutive to the\u00a0other sentences. For the offence of causing or inciting a child aged between 13 and 15 to engage in sexual activity (non-penetrative) contrary to s.10 of the 2003 Act the\u00a0judge imposed a\u00a0sentence of two years' imprisonment but made this concurrent. For the offence of disclosing a\u00a0private photograph without the\u00a0consent of the individual with the intention of causing that individual distress contrary to s.33 of the Criminal Justice and Courts Act 2015 the\u00a0judge imposed a\u00a0sentence of eighth\u00a0months' imprisonment made consecutive. A\u00a0sentence of eighth\u00a0months was also imposed for the offence of making an\u00a0indecent image of a\u00a0child contrary to s.1 of the Protection of Children Act 1978, but this was made concurrent. For the offence of distributing an\u00a0indecent image of a\u00a0child contrary to s.1 of the 1978 Act a\u00a0consecutive sentence of eighth\u00a0months was imposed. 11 Finally, it should be noted that for the offence of sending an\u00a0electronic communication which is grossly offensive contrary to s.1 of the Malicious Communications Act 1988 a sentence of 16\u00a0months was imposed made consecutive. The\u00a0judge made the\u00a0sentence as high as it was because there was an\u00a0element of racial aggravation. For the other offences, shorter sentences were imposed which were all made concurrent. The\u00a0net result was that the consecutive sentences were as follows: four\u00a0years' imprisonment; sixteen\u00a0months' imprisonment; eight\u00a0months\u2019\u00a0imprisonment, and another sentence of eight\u00a0months' imprisonment. That made a\u00a0total of 80\u00a0months or six\u00a0years and eight\u00a0months. It was and remains common ground that it was appropriate for the judge to give full credit for the early guilty pleas. The\u00a0sentence was therefore the\u00a0equivalent of a\u00a0ten-year sentence (120\u00a0months) if there had been a\u00a0trial. The\u00a0Sentencing Remarks 12 The\u00a0judge noted there were so many separate charges before the court of differing types that it was not possible to deal justly with the case by fixing a\u00a0sentence for each of the charges and making all of them consecutive, even though the\u00a0offending in most instances was separate in the\u00a0sense of involving different complainants or different activities. The\u00a0judge made it clear that he had read with care the\u00a0pre-sentence report and its addendum and the report of Dr\u00a0Todd. The\u00a0judge expressly had regard to the\u00a0principle of totality. He said that it was justifiable to impose some consecutive sentences. He said the\u00a0approach he would take was to breakdown the offending into categories of offence rather than concentrating upon the\u00a0different charges which followed after three sets of criminal investigations against the\u00a0offender. The\u00a0judge was of the\u00a0view that the most serious of the offences concerned causing or inciting sexual activity of a\u00a0child under the\u00a0age of 13. He was right to do so. The\u00a0judge was well aware of the seriousness of the offences in this case. He noted that some of the offences were as serious as can be imagined of offences of their kind. 13 Before the judge, it was the\u00a0prosecution's submission that two most serious offences fell within Category\u00a03B of the relevant guideline. The\u00a0guideline recommends a\u00a0starting point of five years' custody with a\u00a0range of three to eight\u00a0years. As we have noted, the\u00a0judge imposed a\u00a0sentence of four\u00a0years' imprisonment on each of those two charges, but that of course reflected the early guilty pleas. He also made them concurrent to each other. The\u00a0judge was aware that it would not be impossible to impose consecutive sentences, for example in relation to the\u00a0making and possessing of indecent images of children. He chose, however, to make them concurrent for two reasons: first, the\u00a0principle of totality and, secondly, in order to reflect the\u00a0mitigation available to the\u00a0offender in respect of his personal situation, capacity and difficulties. In relation to one offence, as we have said, the\u00a0judge imposed a\u00a0sentence of 16\u00a0months' imprisonment, which reflected the maximum penalty of two years after trial for such an\u00a0offence. He did so because of the\u00a0racial aggravation in that case. 14 The\u00a0judge expressly addressed the\u00a0issue of dangerousness at page 6F to G of his sentencing remarks: "… it will be apparent from what I have said so far that I do not intend to apply the dangerousness provisions now enshrined in section 280 of the Sentencing Act. I have considered those matters, as I am duty bound to do so but, in all the circumstances, which include the fact that the defendant had not otherwise offended, he now being thirty-five, and also the fact that he has admitted these matters, and also the fact that he did not in fact make direct contact with any of the complainants in this case, I certify that I do not intend to apply the dangerousness provisions applicable though they otherwise are." Submissions on behalf of the\u00a0Solicitor General 15 On behalf of the Solicitor General there are two main submissions which are made by Mr\u00a0Holt: (1) The\u00a0judge erred in failing to make a\u00a0finding of dangerousness in respect of the offender. (2) The\u00a0overall sentence did not adequately reflect the\u00a0entirety of the offending behaviour. In particular, it is submitted that it was wrong in principle for all the\u00a0sentences imposed under S20220024 to run concurrently to the\u00a0other sentences. 16 Other more specific criticisms are made in relation to two specific charges in relation to categorisation, for example, but Mr\u00a0Holt candidly accepted at the hearing before us that those were unlikely to make any material difference to the\u00a0overall outcome of this application. 17 It is submitted by Mr\u00a0Holt that there was ample material before court to find the\u00a0offender dangerous. In particular: (1) The\u00a0persistent offending against a\u00a0number of victims. (2) The\u00a0contents of the reports that had been prepared about the\u00a0offender. (3) The\u00a0lack of any genuine remorse. 18 It is submitted that the accounts provided by the offender to the\u00a0report writers showed a\u00a0contrived account that was ultimately not advanced by him. He had suggested that he had a\u00a0benign motivation for his offending, although it is and has been readily accepted on his behalf that that did not provide a\u00a0defence. He had suggested that he committed the\u00a0offences in order to deter children who were making themselves vulnerable on the internet by revealing sexual images of themselves. 19 It is acknowledged that this court has shown a\u00a0reluctance to interfere with the findings by a sentencing judge in relation to dangerousness where the\u00a0judge has correctly applied the\u00a0principles: see R v Johnson [2006] EWCA Crim 2486 at para.11 in which the\u00a0judgment was given by the\u00a0then President of the Queen's Bench Division. He said in relation to applications for reference by the Attorney General that: "The Reference will not succeed unless it is shown that the decision was one which the sentencer could not properly have reached." [Para.11(i)] 20 Nevertheless, it is submitted that where a\u00a0sentence has been found to be unduly lenient, it is open to this court to substitute a\u00a0finding of dangerousness: see R v Thomas and Bonner\u00a0[2022] EWCA Crim 665 at para.39. 21 The\u00a0second main submission and the one on which Mr\u00a0Holt has focused his oral submissions before us today is that the overall sentence was simply too lenient, in particular because there were concurrent sentences imposed for all the offences under committal S20220034. It is submitted that there should at least have been consecutive sentences in relation to some of these offences. By reference to the\u00a0sentencing guideline on totality, it is readily accepted by Mr\u00a0Holt that a\u00a0just and proportionate sentence is not reached simply by adding up individual sentences. A\u00a0reduction is appropriate in order to reflect the\u00a0overall gravity of a\u00a0defendant's offending behaviour. Submissions for the Respondent 22 On behalf of the\u00a0respondent offender, Mr\u00a0Perkins submits that the judge was entitled to reach the\u00a0conclusion that the offender was not dangerous. This was particularly in the light of the traumatic nature of his own early years; the particular difficulties associated with ASD; the\u00a0absence of prior offending; factors pointing away from dangerousness, including the\u00a0absence of any identified psychiatric condition, although in oral submissions Mr\u00a0Perkins has rightly corrected that to accept, in the\u00a0light of Dr\u00a0Todd's report, that there is an\u00a0identified psychiatric condition; and the\u00a0absence of any grooming and\/or direct contact offending. Mr\u00a0Perkins points out that the judge gave this sentencing exercise careful consideration, adjourning it when there was insufficient time to hear it on the first occasion. He also retired for over an\u00a0hour after the hearing and delivered reasoned sentencing remarks. Mr\u00a0Perkins has reminded this court of the terms of s.308 of the Sentencing Act 2020 and he submits that the judge correctly had regard to all of the factors which he was required to consider by the\u00a0legislation. We accept those submissions concerning the\u00a0issue of dangerousness. 23 As this court has said on numerous occasions, including in Johnson, it is not its role on an\u00a0application for reference such as this to substitute its own assessment of dangerousness for that of the sentencing judge. This court's role is the important but limited one of asking whether the judge has erred in principle and whether the conclusion reached was properly open to him. We do not consider that this is a case in which there would be a\u00a0proper basis for this court to interfere with the assessment formed by the sentencing judge after careful consideration of all the relevant factors. 24 Next, Mr Perkins submits that the overall sentence passed was equivalent to a\u00a0total sentence of 10\u00a0years after trial and that that was not unduly lenient, despite the\u00a0number and different types of offence in this case. He also submits that the offences committed under S20220034 were committed between\u00a0April\u00a02020 and\u00a0August\u00a02020 and so broadly overlapped with those committed under committal S20210349 (May to\u00a0September\u00a02020). He submits that it would arguably have been unjust if the judge had imposed consecutive sentences for offences which had been committed contemporaneously with admitted offences, yet delayed in investigation and notification to the\u00a0CPS reviewing lawyer. Overall, Mr\u00a0Perkins submits that this was a\u00a0complicated sentencing exercise conducted conscientiously by an\u00a0experienced judge of the Crown Court. 25 We recognise that this was a\u00a0difficult sentencing exercise, but, with great respect to the\u00a0judge, we have reached the\u00a0conclusion that the\u00a0overall sentence in this case was unduly lenient in accordance with the principles we have identified at the outset of this judgment. In particular, it was wrong to make all of the offences under committal S20220034 concurrent, even having regard to the principle of totality. The\u00a0number of different victims, the\u00a0duration of the offending and its seriousness lead us to the conclusion that it was not reasonably open to the\u00a0sentencing court to make all of those sentences concurrent. On the other hand, it is common ground that justice would not be served by simply making all of the sentences consecutive. 26 In the\u00a0circumstances, what we propose to do is to take the\u00a0sentence passed on the most serious charge under committal S20220034, which was charge two (causing or inciting a\u00a0child under 13 to engage in sexual activity \u2013 non-penetrative), that is for four years' imprisonment, and make that consecutive rather than concurrent. In our judgment, that would lead to a\u00a0total sentence which reflects the\u00a0overall justice of the case. Conclusion 27 For the reasons we have given, we grant the\u00a0application for permission to refer this sentence to this court under s.36 of the\u00a01988 Act. On that reference we make the\u00a0sentence of four\u00a0years' imprisonment on charge 2 under committal S20220034 consecutive to the other sentences. That means that the\u00a0total sentence imposed on the offender is therefore 10\u00a0years and eight\u00a0months' imprisonment. __________<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

LORD JUSTICE SINGH: Introduction 1 This is an application on behalf of His Majesty’s Solicitor General for permission to refer a sentence to this court on the ground that it was unduly lenient under s.36 of the Criminal Justice Act 1988 («the 1988 Act»). 2 The principles to be applied on such application are well established and have been summarised…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[8238],"kji_chamber":[],"kji_year":[32183],"kji_subject":[7612],"kji_keyword":[7621,7922,8346,8348,8347],"kji_language":[7611],"class_list":["post-658868","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-court-of-appeal-criminal-division","kji_year-32183","kji_subject-fiscal","kji_keyword-judge","kji_keyword-offences","kji_keyword-offender","kji_keyword-sentence","kji_keyword-years","kji_language-anglais"],"yoast_head":"\nREX v MARK ANTHONY WILSON - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/ru\/jurisprudences\/rex-v-mark-anthony-wilson\/\" \/>\n<meta property=\"og:locale\" content=\"ru_RU\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"REX v MARK ANTHONY WILSON\" \/>\n<meta property=\"og:description\" content=\"LORD JUSTICE SINGH: Introduction 1 This is an application on behalf of His Majesty's Solicitor General for permission to refer a sentence to this court on the ground that it was unduly lenient under s.36 of the Criminal Justice Act 1988 ("the 1988 Act"). 2 The principles to be applied on such application are well established and have been summarised...\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.com\/ru\/jurisprudences\/rex-v-mark-anthony-wilson\/\" \/>\n<meta property=\"og:site_name\" content=\"Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"\u041f\u0440\u0438\u043c\u0435\u0440\u043d\u043e\u0435 \u0432\u0440\u0435\u043c\u044f \u0434\u043b\u044f \u0447\u0442\u0435\u043d\u0438\u044f\" \/>\n\t<meta name=\"twitter:data1\" content=\"15 \u043c\u0438\u043d\u0443\u0442\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/rex-v-mark-anthony-wilson\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/rex-v-mark-anthony-wilson\\\/\",\"name\":\"REX v MARK ANTHONY WILSON - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/#website\"},\"datePublished\":\"2026-04-23T10:22:25+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/rex-v-mark-anthony-wilson\\\/#breadcrumb\"},\"inLanguage\":\"ru-RU\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/rex-v-mark-anthony-wilson\\\/\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/rex-v-mark-anthony-wilson\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/avocats-en-droit-penal-a-paris-conseil-et-defense-strategique\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Jurisprudences\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/jurisprudences\\\/\"},{\"@type\":\"ListItem\",\"position\":3,\"name\":\"REX v MARK ANTHONY WILSON\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/ru\\\/\",\"name\":\"Kohen Avocats\",\"description\":\"Ma\u00eetre Hassan Kohen, avocat p\u00e9naliste \u00e0 Paris, intervient exclusivement en droit p\u00e9nal pour la d\u00e9fense des particuliers, notamment en mati\u00e8re d\u2019accusations de viol. 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