{"id":650382,"date":"2026-04-22T18:31:39","date_gmt":"2026-04-22T16:31:39","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/r-v-sa\/"},"modified":"2026-04-22T18:31:39","modified_gmt":"2026-04-22T16:31:39","slug":"r-v-sa","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/r-v-sa\/","title":{"rendered":"R v SA"},"content":{"rendered":"
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LADY JUSTICE CARR: Introduction 1. This is an application by His Majesty's Solicitor General for leave to\u00a0refer a\u00a0sentence imposed in the Crown Court at Woolwich which he\u00a0regards as\u00a0being unduly lenient. We give leave. 2. The Reference arises out of the physical abuse of\u00a0a\u00a0nine-year-old by\u00a0his father in circumstances which we shall come to\u00a0explain. It\u00a0is not clear to us what precise consideration was given at\u00a0the Crown Court to\u00a0the necessity or otherwise of\u00a0an\u00a0order under sections\u00a045 or 45A\u00a0of\u00a0the Youth Justice and Criminal Evidence Act 1999. At\u00a0the outset of\u00a0the hearing before us we made an\u00a0order under section\u00a045 granting anonymity to\u00a0the boy and his siblings who gave evidence in the trial, to\u00a0whom reference has been made in the course of this hearing and to which reference will be made in our judgment. The order will apply until the children's eighteenth birthdays. 3. In consequence, the boy victim will be described by us\u00a0as\u00a0E, and his siblings by\u00a0other letters as\u00a0appropriate. The welfare of\u00a0the children demands that they be not named. They are of school age and the emotional harm likely to\u00a0be\u00a0caused to them by\u00a0naming them in a case of this kind is plain and obvious. So nothing may be reported which may lead to the identification of\u00a0any of\u00a0the children. We specifically prohibit the naming of\u00a0the area of London where this crime occurred, although the fact that the case was heard in the Crown Court at Woolwich may be reported. In consequence of this order, the name of\u00a0the offender will also have to\u00a0be\u00a0anonymised. 4. We emphasise the importance of\u00a0clarity in terms of considering and\/or the making of\u00a0any order under sections\u00a045\u00a0or 45A\u00a0that the outset of\u00a0proceedings in the Crown Court, usually at the PTPH, and at\u00a0the latest at\u00a0the commencement of\u00a0the trial. We do not seek to\u00a0set out any principles as\u00a0to\u00a0when it\u00a0is appropriate to\u00a0make an\u00a0order, but there is a\u00a0statutory regime to\u00a0be\u00a0followed. 5. The offender is now 66\u00a0years old. On 10\u00a0June\u00a02022, the sixth day of\u00a0his trial before His Honour Judge Mann KC (\u201cthe Judge\u201d), he\u00a0pleaded guilty to\u00a0cruelty to\u00a0a\u00a0person under 16\u00a0years, contrary to\u00a0section\u00a01(1) of\u00a0the Children and Young Persons Act 1933. As\u00a0we have indicated, the victim of the offence was his son, then aged nine. 6. On 12\u00a0October\u00a02022 the offender was sentenced to\u00a0a\u00a0suspended sentence order, comprising a\u00a0custodial term of\u00a022\u00a0months, suspended for 12 months, with a\u00a0two-month electronic curfew between the hours of 7.00 p.m. and 7.00\u00a0a.m. The offender was also ordered to\u00a0pay \u00a3500 in compensation to\u00a0E\u00a0and costs in the sum of\u00a0\u00a3250. A\u00a0victim surcharge was applied. 7. On 22\u00a0January\u00a02021 the offender had assaulted E\u00a0by\u00a0repeatedly striking him with metal rods and a\u00a0belt. After the physical assault was over, the offender told E\u00a0to\u00a0stand in a\u00a0corner in the living room with his arms raised above him in what is known as a "stress position". The incident took place at\u00a0the family home and lasted for several hours. It was witnessed directly by\u00a0one of\u00a0E's siblings (Y); another sibling (Z) was upstairs at\u00a0the time but heard E's cries of\u00a0pain. When E's mother (\u201cthe mother\u201d) returned home, she took E\u00a0to\u00a0hospital and the matter was reported to\u00a0the police. 8. Police subsequently conducted a video-recorded interview with E, Y, Z and the mother. The offender was charged with offences of\u00a0child cruelty in respect of\u00a0each child. The cross-examination of the children was pre-recorded, pursuant to section 28 of the Youth Justice and Criminal Evidence Act 1999. 9. As indicated, the offender pleaded guilty child cruelty in respect of\u00a0E (count 2). The counts in relation to the other children were directed to lie on the file. 10. For the Solicitor General it\u00a0is submitted that the Judge fell into error by concluding that the adjusted term fell within the range of\u00a0sentences where the question of\u00a0suspension became relevant and\/or in deciding to\u00a0suspend that sentence. The facts 11. The offender was born in Lagos, Nigeria, and moved to\u00a0the United Kingdom in 1990. At the relevant time he was living in London with the mother, his stepdaughter (Z), aged 17, and his two biological children, E\u00a0and\u00a0Y. The mother also had two adult sons who did not live with them. On 22\u00a0January\u00a02021 and during a\u00a0period of\u00a0national lockdown, E\u00a0was at home with his sisters during the day. The mother had been informed by\u00a0E's\u00a0school that E\u00a0had not been attending his online school classes for the last two\u00a0days. This resulted in E\u00a0being told that he would not be allowed to\u00a0play computer games for some time. The mother then left the home to visit her eldest son. 12. The offender came home from work to\u00a0find E\u00a0using the computer. The mother telephoned him and told him about E\u2019s non-attendance at school. The offender then repeatedly struck E\u00a0across the back using metal sticks or rods which he\u00a0retrieved from a\u00a0basket next to the television in the living room. He also used his belt repeatedly to\u00a0strike E\u00a0on the back, arms and shoulders. E\u00a0cried very loudly. Y witnessed the assault. Z\u00a0was upstairs at the time and heard his cries. When the physical assault had come to\u00a0an\u00a0end, the offender told E\u00a0to hold a\u00a0metal\u00a0stick above his head and face the garden. E remained in this stress position for some two hours. 13. The mother came home on 24\u00a0January\u00a02021 to\u00a0find E\u00a0still in pain. She saw the marks on his body. She confronted the offender who admitted what he had done at that stage but did not accept that his actions were wrong. 14. The mother took E\u00a0to\u00a0hospital where he\u00a0was found to have multiple horizontal bruises across his back and arms, linear in appearance and consistent with the use of\u00a0a\u00a0metal stick-like implement. He also had bruising to\u00a0his shoulders and his head, as well as cuts to\u00a0his hands. The metal sticks that had been used by\u00a0the offender were provided to\u00a0the police subsequently. 15. The offender was arrested on 25\u00a0January\u00a02021. He\u00a0said at that stage that he felt very remorseful but, when interviewed, denied assaulting E or any of his children with a\u00a0stick or belt and denied putting E in a\u00a0stress position. Instead, he\u00a0blamed his wife. He\u00a0said that E\u00a0and the siblings had fabricated these allegations, orchestrated and encouraged to do so by\u00a0his wife. He said that his wife was upset with him over citizenship and the entry of\u00a0her family into this country. 16. Having been charged, the offender was remanded on bail with conditions which included a\u00a0qualifying (electronically-monitored) curfew. He pleaded not guilty throughout the pre-trial period, and the trial commenced on 10\u00a0June 2021 with cross-examination of\u00a0the children under section\u00a028 procedures. The case was then listed for further hearing between 6\u00a0and 10\u00a0June\u00a02022. The recorded evidence of\u00a0the children was played to\u00a0the jury and the mother gave live evidence. After the prosecution had closed its case, the mother discovered text messages that the offender had sent to\u00a0her in\u00a0January\u00a02021 in which he\u00a0had warned her and E\u00a0not to say anything about what had happened to\u00a0E. The offender then offered a\u00a0guilty plea to\u00a0Count\u00a02\u00a0on a\u00a0full facts basis. On the sixth day of\u00a0trial he\u00a0was re-arraigned on Count\u00a02, and pleaded guilty. The sentencing process 17. The case was adjourned for sentence and came before the Judge for sentence on 12\u00a0October\u00a02022. The material or information before the Judge included the following. 18. In terms of antecedents, the offender had only one previous conviction for common assault, dating back to\u00a01996, but we note that that conviction was for an\u00a0assault in respect of\u00a0his first wife. He\u00a0received a\u00a0community order with a requirement to carry out 80 hours unpaid work. 19. Further, there was a\u00a0Pre-Sentence Report dated 27\u00a0July\u00a02022 in which it\u00a0was recorded that the offender maintained his innocence. He had only pleaded guilty, he\u00a0said, to\u00a0save his job. He\u00a0denied assaulting E. He denied using a\u00a0belt. He\u00a0had only gently tapped\u00a0E\u00a0twice on the shoulder and the injuries had in fact been caused by\u00a0the mother. He stated that his wife had instructed the children to manufacture false accounts against him. He\u00a0demonstrated no empathy or concern for the welfare of\u00a0his children, nor any remorse. 20. There was also a\u00a0Victim Personal Statement prepared by\u00a0the mother. In that statement she set out the impact of\u00a0the offending and the court proceedings on her. She described the negative impact on her health and on her emotional state, her difficulties sleeping, the fact that she had been physically sick from stress and was crying a\u00a0lot. She could not believe that the offender had made up a\u00a0story about her. She referred to\u00a0her past relationship with the offender, but also how her bond with her children had become stronger and that the children were now much happier with the offender not living with them. 21. The Judge sentenced the offender on a\u00a0full facts basis, noting the fact that the suggestion of innocence made by\u00a0the offender to\u00a0the probation officer had not been maintained at\u00a0the sentencing hearing. He\u00a0said there would be no credit for the offender's guilty plea, that plea having been entered two thirds of the way through trial. As\u00a0for impact on the victim, the Judge recorded that he had been informed that E\u00a0did not wish to\u00a0describe the impact on him because he\u00a0was still too traumatised. The Judge stated: "[…] There is nothing to\u00a0say the extent to\u00a0which, if at all, E\u00a0had any sort of psychological damage, but just common sense that he must have been very upset about it and those sorts of feelings against one's parents can be very long-standing and can affect the rest of\u00a0your life, and so you must bear responsible for that [….]" 22. The Judge placed culpability in Category\u00a0A\u00a0of\u00a0the Sentencing Council Guideline on Child Cruelty. The offender had used a\u00a0weapon to\u00a0strike E\u00a0multiple times and it was a\u00a0prolonged incident that went on for hours, with another form of\u00a0cruelty involving the requirement for E\u00a0to\u00a0stand in the stress position. Harm was placed as\u00a0falling between categories 1 and 3. 23. The Judge went on to\u00a0state this: "This offending can be rightly regarded as\u00a0one-off and out of\u00a0character for you and unlikely to\u00a0ever be repeated because the children are not with you now. So you have also your good character and you […] have no access to your children. That may change in the future. I\u00a0recognise that. I\u00a0have to\u00a0bear in mind that there is no suggestion that you are generally a\u00a0danger to\u00a0children.This offence occurred within the home circumstances and on the evidence is unlikely to be repeated. There was evidence during the trial that you were assaulting other children in your family and generally being abusive, but you are not charged\/you have not been convicted of those, but I say that because you must recognise, that as\u00a0you probably do now, that is not the way to\u00a0behave within the context of\u00a0your family or at all. I\u00a0accept that this was not done because you are a\u00a0bad person or that you were trying to\u00a0be\u00a0malicious but because you were concerned about the welfare of\u00a0your children, and I also accept that in all other respects E\u00a0was looked after well, well-educated and very well brought up. I\u00a0have to\u00a0put all of\u00a0that in the equation." 24. The Judge did not specifically refer to any aggravating factors when passing sentence, but did refer to\u00a0mitigating factors, which he\u00a0identified as\u00a0the offender's age, his previous good character, the fact this was an\u00a0isolated incident, that there was no evidence that E\u00a0had suffered prolonged psychological damage and that the incident had been born out of\u00a0concern for E's\u00a0welfare. 25. The Judge concluded that the custody threshold was passed but that a custodial sentence was capable of\u00a0suspension, particularly in light of\u00a0the curfew under which the offender had been placed. He had, as\u00a0we have indicated, been on bail with a\u00a0qualifying curfew throughout the proceedings. Specifically in this regard, the Judge said this: "I\u00a0also have to\u00a0take into account the amount of\u00a0time you have spent on curfew because \u00a0\u0336 qualifying curfew, because you have done the equivalent of\u00a0two years. So if I\u00a0were to\u00a0sentence you today to\u00a0two years' imprisonment, you would almost certainly walk straight out. I\u00a0need to bear that in mind. I\u00a0cannot sentence you twice. I\u00a0cannot give you a\u00a0double sentence just to\u00a0make sure you go to\u00a0prison. That would be quite wrong. I\u00a0have to\u00a0look at the sentence I\u00a0would have passed. So\u00a0how do I\u00a0approach this? Well, first of all, does this pass the custody threshold irrespective of\u00a0all the other factors? Yes, of course it does. So I\u00a0start with the conclusion that this passes the custody threshold. I\u00a0am going to have to\u00a0consider other matters, such as\u00a0your age and previous good character, whether or not this offence is ever likely to be repeated and I\u00a0have to consider the guidelines for dealing with these sorts of\u00a0offences (pleas), and whether there is a possibility of rehabilitation. Given the isolated nature of\u00a0the offence, it seems to me that it would be wrong to\u00a0conclude [that this] is not a\u00a0sentence which is capable of\u00a0being suspended, and I\u00a0pause there because I\u00a0add, and I\u00a0add for the second time in case anyone was considering this– reading about this sentence and\u00a0why I\u00a0have taken the decision I\u00a0have. I\u00a0also have to\u00a0take into account the amount of\u00a0time the defendant has spent on qualifying curfew and so because of that I– I conclude that the most appropriate way to deal with you is as follows […]" 26. The Judge went on to\u00a0impose the suspended sentence order to\u00a0which we have already referred. The Solicitor General's submission 27. Mr\u00a0Lloyd for the Solicitor General recognises that the Judge correctly determined that the offending fell within Category\u00a02A\u00a0of\u00a0the relevant Guideline, but submits that a\u00a0term significantly longer than 22 months' imprisonment was merited. The starting point for a\u00a0Category\u00a02\u00a0offence is 3\u00a0years\u2019 custody, with a\u00a0range of\u00a02\u00a0to\u00a06\u00a0years' custody. The Judge did not specifically refer to\u00a0any aggravating factors increasing the seriousness of the offence. Those factors merited, in Mr\u00a0Lloyd's submission, a\u00a0significant uplift from the starting point of\u00a03\u00a0years. 28. So far as mitigating factors were concerned, the fact that this was an\u00a0isolated incident born out of\u00a0concern for the welfare of\u00a0E was not properly to\u00a0be\u00a0treated as\u00a0a positive mitigating factor. The Judge himself recognised that there was evidence during trial of\u00a0assault or\u00a0general abusive behaviour involving other children in the family. So far as motivation was concerned, this was merely a\u00a0question of\u00a0an\u00a0absence of\u00a0a\u00a0further aggravating feature, as opposed to\u00a0positive\u00a0mitigation. In the alternative, Mr\u00a0Lloyd submits that too much weight was given to these factors by\u00a0the Judge. 29. In short, it\u00a0is said that the downward adjustment to\u00a022\u00a0months, taking into account all aggravating and mitigating factors, was simply far too great. It did not reflect the overall seriousness of\u00a0this offending. 30. For the offender, Miss\u00a0Carter submits that the Judge, who was well placed to\u00a0sentence the offender having observed him over the course of\u00a0a\u00a0six-day trial, followed a\u00a0considered and balanced approach and that the final sentence that he\u00a0imposed could not properly be described as unduly lenient. She submits that he\u00a0was entitled to\u00a0accept her submissions at the time to\u00a0the effect that this offence could be distinguished from other culpability\u00a0Aoffending. It was said that the offender did not have deliberate disregard for E's\u00a0welfare but rather wanted to\u00a0instil in him proper standards. His offending was not of a\u00a0sadistic or cruel nature. E\u00a0and his siblings were clearly otherwise well looked after and provided for. All of this, coupled with the offender's good character, justified the custodial term of\u00a022\u00a0months. 31. It\u00a0was then well within the judge's discretion, submits Miss\u00a0Carter, to\u00a0impose a\u00a0suspended sentence, bearing in mind at this stage additionally the significant amount of\u00a0time spent by\u00a0the offender on curfew. If we were to\u00a0conclude that the sentence below was unduly lenient, Miss\u00a0Carter invites us to\u00a0give anxious consideration to\u00a0maintaining a\u00a0suspended sentence but with more onerous conditions. Discussion 32. References under section\u00a036 of\u00a0the Criminal Justice Act 1988 are made for the purpose of the avoidance of\u00a0gross error, the allaying of widespread public concern at what may appear to\u00a0be\u00a0an unduly lenient sentence, to the preservation of public confidence in cases where a\u00a0Judge appears to have departed to a\u00a0substantial extent from the norms of\u00a0sentencing generally applied by\u00a0the courts in cases of\u00a0a\u00a0particular type (see Attorney General's Reference No. 132 of\u00a02001 (R\u00a0v\u00a0Johnson) [2002] EWCA Crim 1418; [2003]\u00a01\u00a0Cr App\u00a0R\u00a0(S)\u00a041 at [25]). We remind ourselves that the hurdle is a\u00a0high one for appellate interference to\u00a0be\u00a0justified. The sentence in question must be not only lenient, but unduly so. 33. There is rightly no criticism made of the Judge's assessment of this offending as\u00a0Category\u00a02A\u00a0offending, carrying a\u00a0starting point of\u00a03\u00a0years' custody with a\u00a0range of\u00a02\u00a0to\u00a06\u00a0years. 34. There were, however, multiple aggravating factors which, in our judgment, appear to have been overlooked. First, and significantly, there was the presence of\u00a0other children. This was a\u00a0significant factor on the facts here, given that one eight-year-old sibling was actually in the room when the offending took place and another in a\u00a0position to\u00a0hear E's\u00a0distress. This was to\u00a0witness the punishment of\u00a0one child, instilling fear in others of\u00a0similar treatment so far as they were concerned. 35. Additionally, there was the failure to\u00a0seek medical help, and also significantly, the fact that the offender wrongly sought to\u00a0blame others. There was also his attempt to conceal his offending in the form of\u00a0the text messages sent to the mother. 36. By\u00a0way of\u00a0mitigation there was the offender's limited previous offending history and the fact that this was an\u00a0isolated incident, albeit that we accept Mr Lloyd\u2019s submission that in reality this was not a\u00a0question of a\u00a0positive mitigating factor but at best neutral. It\u00a0is, beyond that, difficult to see what significant, if any, further mitigation there was byreference to\u00a0the offender's age or the lack of\u00a0offending on other children or the offender\u2019s motivation. 37. In terms of lack of\u00a0evidence of\u00a0long-term psychological damage to\u00a0E, as\u00a0the Judge commented, as\u00a0a\u00a0matter of\u00a0common sense, real trauma to\u00a0E\u00a0must have been caused. The level of\u00a0harm was, in any event, addressed in the question of\u00a0categorisation of\u00a0harm, as\u00a0opposed to\u00a0being a\u00a0question of mitigation. 38. On the face of his sentencing remarks, the Judge appears to have been concerned as to how to\u00a0recognise the time spent by\u00a0the offender on curfew. The Judge should not have been distracted by\u00a0that factor, at least at the outset; it\u00a0was not relevant to\u00a0the question of\u00a0determining the correct length of custodial sentence. It would be a\u00a0question of\u00a0credit under section\u00a0325\u00a0of\u00a0the Sentencing Act 2020, in due course, subject to\u00a0the question of\u00a0suspension. 39. The starting point of three years for this Category 2A offending, thus, fell to\u00a0be\u00a0increased significantly to\u00a0take account of\u00a0the aggravating factors that we have identified. These factors merited an increase of\u00a0up to\u00a0at least three and a\u00a0half years. With mitigation, that term could not be reduced, in our judgment, to\u00a0a\u00a0term of\u00a0less than 3\u00a0years. The potency of\u00a0mitigation available generally was, in our judgment, reduced materially by\u00a0the offender's denial of\u00a0guilt until so late in the day and, for example, his repeated denial of guilt to the author of\u00a0the Pre-Sentence Report. 40. In our judgment, the offending warranted a custodial term of not less than three years. There was no proper basis for the Judge to have reached a custodial term outside the range for Category\u00a02A offending. In such circumstances, suspension was not an\u00a0option. 41. For all these reasons, and seen in this light, the term that the\u00a0Judge imposed was not only lenient, but unduly so. Conclusion 42. For these reasons, we allow the Reference. The sentence of\u00a022\u00a0months' imprisonment will be quashed and replaced by\u00a0a\u00a0sentence of\u00a0three years' imprisonment. The offender will receive full credit for half the time that he has spent under curfew if that curfew, as we understand it did, did qualify under the provisions of\u00a0section\u00a0325 of\u00a0the Sentencing Act 2020. On the information before us, the relevant total period is 340\u00a0days. If this period is mistaken, the court will order an\u00a0amendment of\u00a0the record for the correct period to\u00a0be\u00a0recorded.<\/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":"

LADY JUSTICE CARR: Introduction 1. This is an application by His Majesty’s Solicitor General for leave to refer a sentence imposed in the Crown Court at Woolwich which he regards as being unduly lenient. We give leave. 2. The Reference arises out of the physical abuse of a nine-year-old by his father in circumstances which we shall come to explain….<\/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":[8244,7621,8047,8346,8348],"kji_language":[7611],"class_list":["post-650382","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-children","kji_keyword-judge","kji_keyword-mother","kji_keyword-offender","kji_keyword-sentence","kji_language-anglais"],"yoast_head":"\nR v SA - 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\/zh-hans\/jurisprudences\/r-v-sa\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"R v SA\" \/>\n<meta property=\"og:description\" content=\"LADY JUSTICE CARR: Introduction 1. This is an application by His Majesty's Solicitor General for leave to refer a sentence imposed in the Crown Court at Woolwich which he regards as being unduly lenient. We give leave. 2. 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