R v Keith Bunce

When sentencing multiple offences forming a sustained course of conduct, the court may impose a single overall sentence reflecting the offending as a whole. It should not simply add individual notional sentences and then apply a totality discount. A persistent pattern of abuse may support high harm and culpability where it demonstrates planning, recording or violence, without impermissible double counting. Purported support given by an offender to a vulnerable victim may aggravate the offending where it formed part of grooming and exploitation. An appellate court will not interfere with a severe sentence that was reasonably open to the trial judge and is not manifestly excessive.

The appellant was sentenced at the Crown Court at Bristol on 25 September 2024 to 28 years’ imprisonment for multiple sexual offences and assaults committed against a vulnerable young woman over approximately seven months. He appealed with leave, arguing that the sentencing judge had misapplied the sentencing guidelines, treated the course of conduct as establishing excessive harm and culpability, failed to give sufficient weight to mitigation, and imposed a manifestly excessive sentence. The central issue was whether the overall sentence properly reflected culpability, harm and totality.

Appeal dismissed. The overall sentence of 28 years was severe but not manifestly excessive and was reasonably open to the sentencing judge.

1. Harm and culpability. The persistent and repeated abuse, viewed as a course of conduct rather than as isolated or opportunistic offences, supported placing harm and culpability in the higher brackets. The circumstances demonstrated significant planning. The recording of some offences and evidence of previous violence were additional relevant features. This was not double counting, nor an improper transfer of harm factors into culpability.
2. Totality. The sentencing judge was entitled to identify a single sentence for the offending as a whole. The individual notional sentences exceeded 170 years, but it would have been wrong simply to add them and then apply a discount. The proper approach was to ensure that the sentence reflected all the offending without becoming disproportionate.
3. Mitigation and aggravation. The appellant’s purported emotional and practical support for the victim could not operate as mitigation. The trial judge had found that he recruited and groomed her for his sexual pleasure, so the support formed part of the aggravating context. Attempts to pressure the victim to withdraw her allegations were not relied upon to elevate the sentence because the appellant had separately been prosecuted and sentenced for perverting the course of justice.
4. Appellate review. The trial judge had heard all the evidence and was best placed to assess culpability and harm. The sentence fell within the range reasonably open to him in the particular circumstances. The appeal was therefore dismissed.

• Court of Appeal (Criminal Division): On 23 July 2025, in [2025] EWCA Crim 1157, dismissed the appeal against sentence.
• Crown Court at Bristol: On 25 September 2024, the appellant was sentenced to a total of 28 years’ imprisonment for multiple sexual offences and assaults.