R v Sakeem Rhoje Gordon

For unlawful act manslaughter, culpability may be high where an offender knowingly participates in a planned robbery carrying a high risk of really serious harm. A serious previous record may justify moving to the top of the applicable guideline range. Dangerousness may be assessed using risk reports and prison conduct, with caution about disputed allegations. A dangerous offender does not automatically require a discretionary life sentence. Age and relative immaturity may instead support an extended determinate sentence for public protection.

The court sentenced Sakeem Gordon after his murder conviction was substituted with manslaughter in the earlier judgment, [2025] EWCA Crim 1611, following an earlier judgment in the same proceedings dated 31 July 2025, [2025] EWCA Crim 1045. The manslaughter arose from his participation in a planned robbery during which Vishal Gohel was murdered. Concurrent sentences for conspiracy to rob and possession of a bladed article remained unchanged. The issues were the appropriate manslaughter sentence, dangerousness and whether a discretionary life sentence was required.

1. The court imposed an extended determinate sentence of 20 years for manslaughter, comprising 16 years’ custody and a four-year licence period. The concurrent sentences of 11 years for conspiracy to rob and six months for possession of a bladed article remained in place.

2. The offence fell within category B for unlawful act manslaughter. Gordon knew that the planned robbery carried a high risk of really serious harm, and the offence was not impulsive. The court therefore increased the starting point to the top of the range, 16 years.

3. Gordon’s substantially worse criminal record, including previous robbery and weapons offences, was a significant aggravating factor. His difficult upbringing was relevant mitigation, but its weight diminished as further offending continued.

4. The court considered the pre-sentence material, updated risk assessment and prison conduct. It exercised caution about the details of disputed allegations but attached significance to the frequency of violent and aggressive incidents. Gordon was consequently a dangerous offender.

5. The finding of dangerousness did not itself require a discretionary life sentence. The offence was not so serious as to make life imprisonment necessary. Gordon’s age and relative immaturity were principal factors. An extended determinate sentence was appropriate to protect the public.

• Court of Appeal (Criminal Division): Earlier judgments in the same proceedings were given on 31 July 2025 under [2025] EWCA Crim 1045 and at the start of the present hearing under [2025] EWCA Crim 1611. The present judgment imposed sentence for the substituted manslaughter conviction.
• Crown Court at St Albans: Concurrent sentences of 11 years for conspiracy to rob and six months for possession of a bladed article had been imposed. The present judgment dealt only with manslaughter.