R v Yossa Maunders

Totality requires a sentence for multiple offences to reflect all the offending, harm, culpability and relevant aggravating and mitigating factors, while remaining just and proportionate.

Offences against each victim may properly attract concurrent sentences, with consecutive sentences for offending against different victims. No further reduction is required where that structure fairly reflects the overall criminality. Where an offender is already serving a sentence, the court must first sentence the new offences and then consider whether any allowance is justified. It need not simply aggregate all offending and deduct the earlier sentence. Concurrency may itself provide a real benefit, particularly where release on licence would expose the offender to recall. An opportunity to disclose other offending may also justify withholding any further reduction.

The appellant pleaded guilty to fourteen historic sexual offences against two child victims. On 22 May 2025, the Crown Court at Cardiff imposed concurrent sentences for offences against each victim, consecutive sentences between the victims, and ordered the new sentences to run concurrently with a sentence imposed for similar offending following an earlier appeal in R v Maunders [2025] EWCA Crim 579.

With leave, the appellant appealed against sentence. He argued that totality had not been adequately reflected either between the two victims or between the current offences and the earlier sentence, so that the overall sentence was manifestly excessive. The central issue was whether the sentencing structure produced a just and proportionate total sentence.

1. Disposition. The appeal against sentence was dismissed. The sentence was not unjust, disproportionate or manifestly excessive.
2. Offences against two victims. The Totality Guideline requires the overall sentence to reflect all the offending behaviour, its harm and culpability, relevant aggravating and mitigating factors, and proportionality. It was just and proportionate to make the offences against each victim concurrent, while making the sentences for the two victims consecutive. The offending involved fourteen grave sexual offences against vulnerable children over many years. The appellant had been an adult for some of the offences and had exploited the children’s vulnerability and fear. No further reduction between the victims was required.
3. Earlier sentence. Where offences are sentenced after an earlier sentence, the court should first determine the appropriate sentence for the instant offences, including totality between those offences. It then has a discretion whether to allow for the earlier sentence after considering all the circumstances. The exercise is not a simple calculation in which a global sentence is constructed and the earlier sentence deducted. Relevant considerations include the similarity and overlap of the offending, whether the offender had an opportunity to disclose the further offences, and whether allowance would confer an undeserved benefit.
4. Application to the earlier sentence. The concurrency ordered with the 2021 sentence had a real effect. Had the appellant been released at the halfway point, he would still have been liable to recall for the remaining period, which was instead served concurrently with the new sentences. The earlier offending involved different victims and was substantially prior to the current offending, so consecutive treatment was generally appropriate. The appellant had also failed to disclose the current offending when dealt with in 2021, despite having the opportunity to do so. That was a relevant consideration under the Guideline and justified making no further allowance.
5. The fact that the appellant had already served three and a half years for similar offending did not render the new sentence unjust or disproportionate. The appeal was therefore dismissed.

• Court of Appeal (Criminal Division): On 9 July 2026, dismissed the appeal against sentence.
• Court of Appeal (Criminal Division): In R v Maunders [2025] EWCA Crim 579 , quashed an extended sentence imposed for earlier sexual offences and substituted a determinate sentence of seven and a half years, with concurrent sentences on other counts.
• Crown Court at Cardiff: On 26 July 2024, the appellant pleaded guilty to fourteen sexual offences. On 22 May 2025, he was sentenced to concurrent sentences for offences against each victim, consecutive sentences between the victims, and concurrency with the earlier sentence.