R v Mohammed Qasim

Where murder is committed during a robbery within paragraph 3(2)(c) of the Sentencing Act 2020, 30 years is the statutory starting point for the minimum term. The sentencing judge must balance aggravating and mitigating features, but an appellate court will generally respect the assessment of an experienced judge who heard the evidence unless a relevant matter was omitted or the approach was flawed. Youth may justify moving below the starting point where there is evidence of particular immaturity showing that chronological age does not reflect actual maturity. Parliament’s graduated starting points mean that a particularly serious murder committed by an 18-year-old may engage the 30-year starting point, or one very near to it. Youth alone did not justify a substantial reduction for a 22-year-old without evidence of particular immaturity.

Following a trial at the Crown Court at Birmingham, Mohammed Qasim was convicted of conspiracy to rob and murder. On 26 April 2024 he was sentenced to life imprisonment with a minimum term of 30 years, reduced to 29 years and 142 days for time spent on remand. The murder was treated as having been committed during a robbery, bringing it within paragraph 3(2)(c) of the Sentencing Act 2020.

The appeal concerned the minimum term. The appellant accepted the 30-year starting point but argued that his youth, vulnerability, drug addiction, exploitation, lack of premeditation and previous good character should have led to a substantially lower term. The central issue was whether the sentencing judge had properly balanced those matters against the aggravating features.

The appeal was dismissed. The minimum term of 29 years and 142 days remained in force.

1. The court accepted that the murder fell within paragraph 3(2)(c) of Schedule 21 to the Sentencing Act 2020. The correct statutory starting point was therefore 30 years. The conspiracy to rob was wholly subsumed within the minimum term for the murder.
2. The sentencing judge had heard the evidence at two trials and was best placed to assess the competing aggravating and mitigating features. He had considered the detailed planning, the disposal of the knife and phone or SIM card, and the flight to Pakistan. He had also taken account of the appellant’s vulnerability, exploitation, age, previous good character and the absence of premeditation. The appellant identified no relevant matter which the judge had omitted.
3. In relation to youth, paragraph 5A of Schedule 21 contains graduated starting points for child defendants. Parliament must be presumed to have taken account of developing maturity. Thus, a particularly serious murder committed by an 18-year-old may engage the paragraph 3 starting point of 30 years or very near to it. A court may nevertheless move down from the starting point where evidence shows particular immaturity and chronological age does not reflect actual maturity: see R v Kamarra-Jarra [2024] EWCA Crim 198.
4. There was no evidence of particular immaturity in this case. The appellant was 22 when he committed the murder. His youth and vulnerability had been considered, but they did not justify reducing the minimum term below the result reached by the sentencing judge.

The court also confirmed under section 33 of the Sentencing Act 2020 that a pre-sentence report was unnecessary.

• Court of Appeal (Criminal Division) [2025] EWCA Crim 1248 (4 September 2025): appeal against the minimum term dismissed.
• Crown Court at Birmingham: following conviction on 22 April 2024, the appellant was sentenced on 26 April 2024 to life imprisonment with a minimum term of 30 years, less time spent on remand.