{"id":672960,"date":"2026-04-24T14:42:49","date_gmt":"2026-04-24T12:42:49","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/az-re-2\/"},"modified":"2026-04-24T14:42:49","modified_gmt":"2026-04-24T12:42:49","slug":"az-re-2","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/az-re-2\/","title":{"rendered":"AZ, Re"},"content":{"rendered":"
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LORD JUSTICE WILLIAM DAVIS: 1 The\u00a0provisions of the Sexual Offences (Amendment) Act 1992 apply to the\u00a0offences with which we are concerned. No matter relating to the\u00a0persons against whom the offences were committed shall, during their lifetime, be included in any publication if it is likely to lead members of the public to identify them as victims of the offences. Given the\u00a0relationship between the\u00a0offender and the persons to whom the\u00a01992 Act gives protection, we shall refer to the\u00a0offender throughout as "AZ". Were he to be identified, this would be likely to lead to the identification of his victims. Introduction 2 On 17\u00a0December\u00a02021 AZ was sentenced by HHJ\u00a0David Potter sitting in the\u00a0Crown Court at Liverpool to an extended determinate sentence of 17\u00a0years pursuant to s.279 of the\u00a0Sentencing Act 2020. The\u00a0custodial term was 12\u00a0years' imprisonment and the\u00a0extended period of licence was five years. That was the\u00a0sentence imposed in respect of Count\u00a01 on the indictment which charged rape of a\u00a0child under the\u00a0age of 13. Concurrent determinate terms of 40\u00a0months' imprisonment were imposed on Counts 2 and 3 which charged sexual assault of a\u00a0child under the\u00a0age of 13. The\u00a0same sentence was imposed on Count\u00a04 – making indecent photographs of a\u00a0child. The\u00a0same offence was charged on Count\u00a05, where the\u00a0sentence was 16\u00a0months' imprisonment. On Count\u00a06 a\u00a0sentence of four months' imprisonment was imposed for distributing an\u00a0indecent photograph of a\u00a0child. All of the\u00a0determinate terms were ordered to run concurrently with each other and with the\u00a0extended determinate term. 3 AZ made his first appearance at the Magistrates' Court on 19\u00a0October\u00a02021. He indicated pleas of guilty at that point. He was sent to the\u00a0Crown Court. He pleaded guilty to the\u00a0indictment at the PTPH in line with the\u00a0indication he had given earlier. Sentence was adjourned to permit the\u00a0preparation of a\u00a0presentence report and a\u00a0psychiatric report. The\u00a0primary purpose of the reports was to assist the\u00a0judge in his assessment of risk and dangerousness. 4 The Solicitor General seeks leave, pursuant to s.36 of the Criminal Justice Act 1998, to refer the\u00a0sentence to this court as unduly lenient. The\u00a0Facts 5 AZ is now 30. He was born in\u00a0January\u00a01992. He married in 2015. There are two children of the marriage: a\u00a0son born in 2017, to whom we shall refer as "RO"; a\u00a0daughter born in 2019, to whom we shall refer as "EM". At the time of the offences in\u00a0September\u00a02021 the\u00a0family lived in Southport. AZ worked in a\u00a0warehouse locally. He had no criminal convictions. To all outward appearances he enjoyed a\u00a0normal family life. However, in\u00a0September\u00a02021 he committed extremely serious sexual offences against both of his very young children. 6 On 14\u00a0September\u00a02021 early in the\u00a0morning on a\u00a0sofa in the\u00a0family home AZ raped his two-year-old daughter. What he did is not in doubt, because he filmed what he did on his mobile telephone. The\u00a0video later recovered from his telephone lasted for about 28 seconds. It showed EM sat on the sofa naked from the waist down with her legs apart. AZ knelt in front of her. His lower half was naked with his penis erect. Initially, he put his penis towards the\u00a0area of EM's anus. He then rubbed his penis against the\u00a0front of EM's vagina. The tip of his penis entered her vagina. At around 10 seconds into the video EM closed her legs. AZ pushed them apart so that he could continue to rub his penis against her vagina. He held her legs apart when EM tried to close them again. What happened after the video finished is not known. She was too young to be interviewed. 7 This was not the\u00a0only occasion on which AZ sexually abused his daughter. On at least one occasion in\u00a0September\u00a02021, he rubbed his penis against her vagina and ejaculated over her. On one such occasion RO, the\u00a0four-year-old son, was present and watched what happened. On 9\u00a0September\u00a02021 AZ took some still images of his daughter. They were taken at the same time of the morning as the\u00a0video recording was made. They showed her naked on her back with her legs apart and her vagina exposed. On 21\u00a0September he distributed one of those images. 8 The\u00a0sexual abuse of EM first came to light when AZ communicated on an\u00a0app called KIK used by those interested in sex with children with someone whom he believed had a\u00a0mutual interest in child abuse. In fact, that person was an\u00a0undercover officer with the National Crime Agency. AZ told the\u00a0officer that he was actively abusing his daughter. He sent an\u00a0image of EM and asked whether he should apply more cream to her vaginal area to help with recovery. He said that he had "put his tip in both holes". He stated that he planned to abuse his daughter again the\u00a0following week when his wife was at work. AZ also said that he had attempted sexual activity with his son, but that he had not got very far because his son "just whinges". 9 AZ was identified. He was arrested at his home on 29\u00a0September\u00a02021. When interviewed, he admitted engaging in conversations on the\u00a0KIK app and sending a\u00a0photograph of his daughter. He said that the content of his conversation was fantasy. He was bailed pending further investigation. His mobile telephone was taken away for examination. 10 AZ lived with his mother after being bailed. The\u00a0children stayed with his wife. On 8\u00a0October\u00a02021 she was bathing the\u00a0children. She noticed a\u00a0tube of lubricant in the\u00a0bathroom. Her son, RO, told her that AZ had put "the\u00a0cream" on his hand and put his penis up his bottom so that it hurt. RO said that EH had been there when this happened. On 16\u00a0October the\u00a0police received the\u00a0results of the examination of the offender's mobile telephone. These revealed the\u00a0video and the still images. He was interviewed again on 18\u00a0October\u00a02021. AZ now admitted sexually assaulting his daughter on two separate occasions, saying that the tip of his penis could have entered her vagina though he did not intend that to happen. He said the abuse was not planned. He had ejaculated on one occasion. The\u00a0offender also admitted sexually assaulting RO by rubbing his penis against his bottom. He said he had never penetrated RO. Material Considered by the\u00a0Judge 11 Neither child was interviewed at any stage of the investigation. It is clear to us that both were regarded as too young. The\u00a0offender's wife made a\u00a0victim personal statement. She explained that there had been a\u00a0noticeable change in her son's behaviour. He was very protective towards his sister. He had said, "I\u00a0saw daddy hurt EM and told him to stop it." She described RO as "no longer that carefree happy four-year-old boy". She said that AZ's actions had "completely destroyed our family". 12 There was a\u00a0pre-sentence report from an\u00a0experienced Probation Officer. In the\u00a0assessment of the risk of serious harm, the\u00a0author of the report said this: "[AZ's] behaviour can be described as extreme. It is rare, in my experience, to see such clear evidence of such serious sexual offending behaviour against such young victims. [AZ] is the father of the victims and was supposed to be caring for them at the time of the offences. As such, one element of this case is the inherent gross breach of trust. The extremely young ages of the victims make it difficult to predict the\u00a0long-term consequences for them but it must be the\u00a0case that [AZ] exposed them to the\u00a0risk of serious psychological harm. It is quite possible that his actions could also have caused them serious physical harm, although, thankfully, this does not appear to have materialised. The\u00a0fact that [AZ] was able to offend in such a\u00a0manner shows that he was capable of breaching innumerable boundaries as to what is viewed as acceptable." 13 There was a\u00a0psychiatric report from Dr Andrew Shepherd. Dr\u00a0Shepherd reviewed AZ's life and experiences at some length. He was unable to provide any psychiatric explanation of the\u00a0offender's actions. We quote from p.24 of his report: "I\u00a0conclude that [AZ] displays no evidence of major mental disorder … But may display some traits suggestive of personality disruption that could have interacted with his subsequent offending behaviour. […] I\u00a0have attempted to offer some tentative initial formulation of [AZ\u2019s] offending behaviour – though the nature of the offence is contradictory to many of his experiences and difficult to understand." The\u00a0Sentence 14 The\u00a0judge referred to the\u00a0relevant guideline in relation to each offence. In respect of the rape of EM, he concluded that there was higher culpability by reason of the abuse of trust and the element of planning which was inherent in the\u00a0act of filming the\u00a0abuse. The\u00a0judge found that harm was in Category\u00a02, because EM was particularly vulnerable due to extreme youth. Since she was only two and a\u00a0half years old, the\u00a0harm approached Category\u00a01. That was because of the extreme nature of the relevant harm factor. A\u00a0category\u00a02A offence indicated a\u00a0starting point of 13\u00a0years' imprisonment with a\u00a0range of 11 to 17\u00a0years. The\u00a0judge noted the\u00a0aggravating effect of the location of the offence and the long-term impact on EM and the wider family unit. 15 In relation to the offences of sexual assault, they were both Category\u00a02A offences in the\u00a0relevant guideline, giving a\u00a0starting point of four\u00a0years with a\u00a0range of three to seven\u00a0years. 16 The\u00a0video\u00a0which AZ took of his rape of EM was in Category\u00a0A in the\u00a0guideline relating to indecent images of children. This provided a\u00a0starting point of six\u00a0years' custody with a\u00a0range of four to nine\u00a0years. The\u00a0judge noted the\u00a0lesser starting points for the other offences concerning indecent images. 17 The\u00a0judge's approach to the\u00a0sentencing exercise was to impose a\u00a0sentence on Count\u00a01, the\u00a0rape of EM, longer than indicated by the\u00a0guideline in order to reflect the\u00a0totality of AZ's offending. The\u00a0offender clearly presented a\u00a0significant risk of causing serious harm for specified sexual offences. Thus, an\u00a0extended determinate sentence would be imposed in relation to that count. Concurrent sentences were imposed on the other counts "to ensure that the overall sentence is just and proportionate". 18 Had AZ pleaded not guilty and been convicted after a\u00a0trial, the\u00a0judge said that an\u00a0extended determinate sentence of 23\u00a0years would have been appropriate, namely a custodial term of 18\u00a0years and an\u00a0extended licence period of five years. Because pleas of guilty had been indicated at the first opportunity, the\u00a0custodial term was reduced to 12\u00a0years. Shorter and concurrent determinate sentences imposed on the other counts reflected the judge's approach. Discussion 19 On behalf of the\u00a0Solicitor General, it is acknowledged that the judge's approach in large measure was correct. He identified and used the\u00a0correct guideline in relation to each offence. He correctly took Count\u00a01 as the\u00a0lead offence. He accepted that the\u00a0extreme youth of EM was critical when determining the\u00a0level of harm. He did not double count in relation to the\u00a0video taken by the\u00a0offender of his act of rape. He found that the offender was dangerous. The\u00a0Solicitor General does not argue that it was wrong to impose an\u00a0extended determinate sentence rather than a\u00a0life sentence. 20 The\u00a0first point at which the judge is said to have fallen into error is in relation to the starting point for the offence of rape of EM. Because she was so young, the\u00a0harm category should have been Category\u00a01. On that basis, the\u00a0starting point was 16\u00a0years' custody before consideration of any aggravating factors. There then should have been a\u00a0significant increase from that starting point to take account of the aggravating factors. By that route, a\u00a0sentence after trial of 18\u00a0years' custody solely for the offence of rape would have been the\u00a0very minimum appropriate sentence. 21 The\u00a0second point flows from the\u00a0first. If the\u00a0proper sentence after trial simply for the offence of rape would have been 18\u00a0years' custody, the\u00a0overall sentence on Count\u00a01 should have been significantly longer in order to reflect the\u00a0totality of AZ's offending. The\u00a0overall sentence required a\u00a0significant uplift to mark the\u00a0offence against RO. The\u00a0indecent image offences were aggravated by the\u00a0fact that images of EM were shared with others. 22 The\u00a0submission on behalf of the Solicitor General is in the\u00a0alternative. Either the\u00a0custodial term in relation to Count\u00a01 should be increased significantly or the\u00a0sentence to be imposed in relation to other offences should commence forthwith, as determinate sentences, with the\u00a0extended determinate sentence to run consecutively. 23 On behalf of the\u00a0offender, Mr\u00a0Heckle argues that a\u00a0reference under s.36 of the Criminal Justice Act 1998 is intended to correct a\u00a0gross error by a sentencing judge. He cites the\u00a0observation to that effect by Thirlwall\u00a0LJ in YZ [2019] EWCA Crim 466. He contends that the judge in this case had considered the\u00a0factual background with great care and had analysed the\u00a0offending properly by reference to the\u00a0Sexual Offences Definitive Guideline. The\u00a0sentence taken by the\u00a0judge as an\u00a0appropriate sentence after a trial was of sufficient length to reflect the\u00a0gravity of the offending. Mr\u00a0Heckle relies on the fact that the offender's full admissions saved any further enquiry with his children. 24 We consider that the correct formulation of what amounts to an\u00a0unduly lenient sentence is still that provided by the\u00a0then Lord Chief Justice in\u00a0Attorney-General's Reference No\u00a04 of 1989 [1990] 1 WLR 41: "A\u00a0sentence is unduly lenient, we would hold, where it falls outside the\u00a0range of sentences which the judge, applying his mind to all the\u00a0relevant factors, could reasonably consider appropriate." 25 By reference to that formulation, we consider that the\u00a0sentence imposed in this case was unduly lenient. We respect the\u00a0fact that the sentencing judge gave very careful consideration to the\u00a0case. His core approach was correct. However, we conclude that the sentence on the\u00a0lead offence did not reflect the\u00a0overall criminality of the offender. 26 Had AZ's offending been restricted to the\u00a0offence of rape of his daughter, a\u00a0custodial term after trial of 18\u00a0years might have been a\u00a0sufficient reflection of the gravity of the offence. It certainly would not have been unduly lenient. We are in no doubt that the offence fell squarely within Category 1 harm in the\u00a0guideline, because of the\u00a0extreme nature of the relevant Category\u00a02 factor, namely "child is particularly vulnerable due to extreme youth". The\u00a0author of the pre-sentence report may not have had the\u00a0guideline in mind when he said what he did as we have quoted above. It is, however, a\u00a0very clear exposition of how extreme the\u00a0harm was in this case. The\u00a0aggravating factor – the\u00a0location of the offence – and the multiple higher culpability factors – planning, gross abuse of trust due to the familial relationship, recording of the\u00a0offence – justified a\u00a0substantial uplift from the starting point of 16\u00a0years. 27 The\u00a0custodial term after trial identified by the\u00a0judge in relation to Count\u00a01, thus, did not reflect the\u00a0following: (i) the\u00a0other sexual assault on EM, which involved the\u00a0offender rubbing his penis against her vagina and ejaculating; (ii) the\u00a0fact that RO was present at the time of this sexual assault; (iii) the\u00a0taking of an\u00a0indecent image at or around the\u00a0time of the other sexual assault, which was shared with others; (iv) the\u00a0sexual assault on RO, which involved the\u00a0offender rubbing his penis against RO's buttocks; (v) the\u00a0fact that EM had been present on this occasion. 28 All of these matters added to the\u00a0overall seriousness of the offending, which the\u00a0judge was required to reflect in the\u00a0lead sentence. In particular, the\u00a0sexual abuse of RO, which was distinct from the abuse of his sister, was very serious. He was only four years old. The\u00a0guideline in relation to sexual assault of a\u00a0child under the\u00a0age of 13 by definition covers a\u00a0wide age range. RO was and is at the lower end of the age range. He suffered clear and obvious psychological effects as a\u00a0result of the abuse. The\u00a0guideline indicates that a\u00a0case of particular gravity may require upward adjustments from the\u00a0starting point, before any further adjustment for aggravating factors. This was a\u00a0case of particular gravity. For that offence, taken in isolation, a\u00a0sentence after trial at the top of the category range would have been required. Even allowing for the\u00a0need to take into account totality and to maintain proportionality, the\u00a0gravity of the\u00a0offence involving RO required a\u00a0substantial uplift to the\u00a0total sentence. 29 We take the\u00a0view that we should follow the\u00a0approach of the sentencing judge. We should determine the\u00a0appropriate sentence to reflect the\u00a0entirety of offending and impose that sentence on Count\u00a01 with shorter determinate sentences on the other counts. The\u00a0determinate sentence in relation to the\u00a0offence involving RO requires adjustment to indicate its seriousness, but that sentence will be ordered to run concurrently. We emphasise that, just as the\u00a0judge sought to represent the\u00a0overall criminality in the\u00a0sentence on Count\u00a01, so do we. Conclusion 30 We give leave to the\u00a0Solicitor General to make a\u00a0reference to this court under the\u00a0provisions of s.36 of the Criminal Justice Act 1988. We find that the sentence imposed on the offender was unduly lenient for the reasons we have set out. Taking the\u00a0same approach as the judge, we conclude that the proper custodial term after a\u00a0trial on all counts would have been 22\u00a0years' imprisonment prior to any issue of future risk of dangerousness. Giving full credit for the pleas of guilty, the\u00a0appropriate custodial term is 14\u00a0years and eight\u00a0months. 31 We quash the\u00a0sentence on Count\u00a01, namely an extended determinate sentence of 17\u00a0years with a\u00a0custodial term of 12\u00a0years and an\u00a0extended licence period of five years. We substitute an\u00a0extended determinate sentence of 19\u00a0years and eight\u00a0months. The\u00a0custodial term will be 14\u00a0years and eight\u00a0months. The extended licence period will be five years. Further, we quash the\u00a0sentence of 40\u00a0months' imprisonment on Count\u00a03 (the sexual assault of RO) and substitute a\u00a0sentence of 54\u00a0months. That determinate sentence will run concurrently with the\u00a0extended determinate sentence imposed on Count\u00a01. All the other sentences we leave untouched. 32 The\u00a0effect of the substituted sentences is the\u00a0offender will serve two thirds of the custodial term of 14\u00a0years and eight\u00a0months before he is eligible for release. Whether he will be released at that point will be a\u00a0matter for the Parole Board to decide, who will only release him if they consider it safe to do so. Whenever he is released, he will remain on licence for any remaining part of the custodial term and for a\u00a0further five years thereafter. __________<\/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 WILLIAM DAVIS: 1 The provisions of the Sexual Offences (Amendment) Act 1992 apply to the offences with which we are concerned. No matter relating to the persons against whom the offences were committed shall, during their lifetime, be included in any publication if it is likely to lead members of the public to identify them as victims of…<\/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":[7621,7925,8348,8448,8347],"kji_language":[7611],"class_list":["post-672960","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-offence","kji_keyword-sentence","kji_keyword-sexual","kji_keyword-years","kji_language-anglais"],"yoast_head":"\nAZ, Re - 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\/az-re-2\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"AZ, Re\" \/>\n<meta property=\"og:description\" content=\"LORD JUSTICE WILLIAM DAVIS: 1 The provisions of the Sexual Offences (Amendment) Act 1992 apply to the offences with which we are concerned. No matter relating to the persons against whom the offences were committed shall, during their lifetime, be included in any publication if it is likely to lead members of the public to identify them as victims of...\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/az-re-2\/\" \/>\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=\"\u9884\u8ba1\u9605\u8bfb\u65f6\u95f4\" \/>\n\t<meta name=\"twitter:data1\" content=\"16 \u5206\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/az-re-2\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/az-re-2\\\/\",\"name\":\"AZ, Re - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\"},\"datePublished\":\"2026-04-24T12:42:49+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/az-re-2\\\/#breadcrumb\"},\"inLanguage\":\"zh-Hans\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/az-re-2\\\/\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/az-re-2\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Jurisprudences\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/\"},{\"@type\":\"ListItem\",\"position\":3,\"name\":\"AZ, Re\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\",\"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. Il assure un accompagnement rigoureux d\u00e8s la garde \u00e0 vue jusqu\u2019\u00e0 la Cour d\u2019assises, veillant au strict respect des garanties proc\u00e9durales.\",\"publisher\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#organization\"},\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/?s={search_term_string}\"},\"query-input\":{\"@type\":\"PropertyValueSpecification\",\"valueRequired\":true,\"valueName\":\"search_term_string\"}}],\"inLanguage\":\"zh-Hans\"},{\"@type\":\"Organization\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#organization\",\"name\":\"Kohen Avocats\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\",\"logo\":{\"@type\":\"ImageObject\",\"inLanguage\":\"zh-Hans\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#\\\/schema\\\/logo\\\/image\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"contentUrl\":\"https:\\\/\\\/kohenavocats.com\\\/wp-content\\\/uploads\\\/2026\\\/01\\\/Logo-2-1.webp\",\"width\":2114,\"height\":1253,\"caption\":\"Kohen Avocats\"},\"image\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#\\\/schema\\\/logo\\\/image\\\/\"}}]}<\/script>\n<!-- \/ Yoast SEO Premium plugin. -->","yoast_head_json":{"title":"AZ, Re - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/az-re-2\/","og_locale":"zh_CN","og_type":"article","og_title":"AZ, Re","og_description":"LORD JUSTICE WILLIAM DAVIS: 1 The provisions of the Sexual Offences (Amendment) Act 1992 apply to the offences with which we are concerned. 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