R v Ijaz Saeed

On a sentence appeal involving controlling or coercive behaviour and related assaults, the appellate court should respect the sentencing judge’s assessment where the relevant guidelines have been correctly applied and totality has been addressed. A lead offence may reflect the offender’s overall criminality, with related assaults treated as aggravating features. The central question is whether there was a sentencing error or whether the overall sentence was manifestly excessive. Sustained domestic abuse, serious violence, significant harm, limited remorse and evidence of future risk may justify a substantial custodial sentence.

Following a summary trial before Leeds Magistrates’ Court, Ijaz Saeed was convicted of controlling or coercive behaviour contrary to section 76 of the Serious Crime Act 2015 and two assaults occasioning actual bodily harm contrary to section 47 of the Offences Against the Person Act 1861. He was committed for sentence under section 14 of the Sentencing Act 2020.

The Crown Court at Leeds imposed an overall sentence of 40 months’ imprisonment, with shorter concurrent terms for the assaults. Leave to appeal was refused on paper. The renewed application challenged the sentence as manifestly excessive and alleged insufficient consideration of totality.

1. Application refused. The court agreed with the single judge that the Recorder had correctly categorised the offences under the relevant sentencing guidelines and had imposed a sentence which properly reflected the available mitigation and the principles of totality.
2. Sentencing structure. The Recorder was entitled to treat the controlling or coercive behaviour as the lead offence and to treat the two assaults as aggravating features when determining a sentence reflecting the applicant’s overall criminality. The existence of separate concurrent terms for the assaults did not demonstrate that totality had been overlooked.
3. Seriousness. The offending was sustained and serious, occurring within an intimate relationship. Particularly serious violence had been used in 2021, and the offences had a serious impact on the applicant’s former partner. The Recorder had also considered the applicant’s previous convictions, limited remorse, risk of future violence, mental health, prison conditions, progress in custody and character references.
4. Disposition. There was no merit in the renewed application. Leave to appeal against sentence was refused, and a loss of time order of 28 days was made.

1. Court of Appeal (Criminal Division): On 2 September 2025, the renewed application for leave to appeal against sentence was refused. The court upheld the overall sentence and directed a loss of time order of 28 days. The decision is reported at [2025] EWCA Crim 1188.
2. Crown Court at Leeds: On 16 September 2024, Recorder Nathan Moxon sentenced the applicant to 40 months’ imprisonment for controlling or coercive behaviour, with shorter concurrent terms for two assaults occasioning actual bodily harm.
3. Leeds Magistrates’ Court: Following a summary trial, the applicant was convicted of the three offences and committed for sentence to the Crown Court.