R v Samura Madhi & Anor

In a sentencing appeal, the appellate court assesses the sentence by reference to the guideline category and range, harm, culpability, aggravating and mitigating factors, and totality. A sentencing judge need not assign numerical or percentage values to individual factors. Youth, mental health, low IQ and vulnerability may together make a sentence manifestly excessive. A separate offence under section 53 of Regulation of Investigatory Powers Act 2000 may attract a consecutive sentence, subject to totality. Where a young offender receives a long custodial sentence under section 250 of Sentencing Act 2020, no separate penalty may be appropriate for another count requiring a different form of custody. An exceptional circumstance may also justify not imposing a mandatory minimum term.

Following a trial at the Crown Court at Teesside, Samura Mahdi and Mohammed Amin Geravandian were convicted of attempted murder arising from a stabbing at Middlesbrough bus station. Mahdi, aged 17 years and three months, was also sentenced for possessing a bladed article. Geravandian, aged 21, was also convicted of failing to disclose the PIN to protected information under section 53 of the Regulation of Investigatory Powers Act 2000. The Crown Court imposed 24 years' custody on each for attempted murder, with additional concurrent or consecutive terms. Both appealed against sentence, principally arguing that insufficient weight had been given to youth, vulnerability, background and mitigation. The central issues were whether the sentences were manifestly excessive and whether the additional sentences were lawful and proportionate.

1. Mahdi's appeal allowed. The offence involved serious injuries, including the loss of a kidney, placing it at the higher end of category 2 harm. Aggravating features included taking and using a knife, planning or premeditation, offending in public and, in Mahdi's case, previous convictions. Mahdi's youth, mental health, low IQ and vulnerability significantly outweighed those factors. His 24-year sentence was therefore manifestly excessive. The court quashed it and substituted 18 years' detention under section 250 of the Sentencing Act 2020 (paras [21]-[23]).
2. A sentencing judge is not obliged to attribute specific percentages or figures to individual factors. The court applied that proposition, stated in R v Hallam [2025] EWCA 199; [2025] 4 WLR 33, in rejecting Mahdi's grounds concerning numerical transparency and the discount for being under 18 (para [19]).
3. Section 250 of the Sentencing Act 2020 did not apply to Mahdi's bladed-article offence. The only available custodial sentence on that count was a detention and training order, and it was inappropriate to impose two different types of custodial sentence. In accordance with the guidance in R v Kovalkov [2023] EWCA Crim 1509, the court ordered no separate penalty. Although section 315 imposed a mandatory minimum term, the long custodial sentence of a different kind on count 1 was an exceptional circumstance justifying its non-imposition (para [24]).
4. Geravandian's appeal dismissed. His lack of previous convictions and age were mitigating factors, but his earlier background difficulties were remote and he had no diagnosed mental health condition. His status as a secondary party had to be assessed alongside his greater age than Mahdi, who was vulnerable and open to exploitation. The Crown Court was entitled to give those matters weight, but the 24-year sentence was not manifestly excessive. The consecutive sentence for the separate section 53 offence was appropriate, subject to the totality principle (paras [20], [25]-[26]).

1. Court of Appeal (Criminal Division) — [2025] EWCA Crim 1401, 14 October 2025. Mahdi's attempted-murder sentence was quashed and replaced with 18 years' detention; no separate penalty was imposed on count 3. Geravandian's appeal was dismissed.
2. Crown Court at Teesside — 8 October 2024. The court sentenced each appellant to 24 years' custody for attempted murder. Mahdi received a concurrent six-month term for possessing a bladed article; Geravandian received a consecutive nine-month term for failing to disclose protected information.