R v Joshua Rennie-Owosu

In sentencing a young offender, reaching 18 is not a cliff edge: maturity may be as important as chronological age. Where consecutive sentences are individually justified, the court must stand back and assess the aggregate sentence. It must make a significant downward adjustment where the total is disproportionate, having regard in particular to the offender’s age and maturity. The fact that offending was committed on bail and after guilty pleas to similar offences may justify consecutive terms, but it does not displace totality. Here, a total of five years for drug-supply offences was manifestly excessive. The proper total was four years, implemented by reducing both consecutive components by six months.

This was an appeal by leave of the single judge against sentence imposed at the Crown Court at Maidstone. On 20 March 2026, Mr Recorder Passmore KC sentenced the appellant for two sets of class A drug-supply offences. The first indictment attracted concurrent terms of 20 months; the second attracted concurrent terms of 40 months, made consecutive because the later offending occurred on bail after guilty pleas to the earlier offences. The total was five years’ custody.

The appellant, aged 18 during the first offending and 20 during the second, relied on totality, youth, immaturity and previous good character. The sentencing remarks were available only in an agreed note, which did not record any express reference to totality. The central question was whether the aggregate sentence was manifestly excessive and whether sufficient allowance had been made for age and maturity.

Appeal allowed. The appeal proceeded on the accepted basis that the judge was entitled to find a significant role for the second indictment and that consecutive sentences were justified because those offences were committed on bail while the appellant awaited sentence for the first indictment.

1. The guideline starting point for the first set of offences, involving a lesser role, was three years and had been reduced to two years before credit for plea. The starting point for the second set, involving a significant role, was four and a half years and had been adopted before credit. The resulting individual sentences, after credit, were 20 months and 40 months. Even if those component sentences were individually justified, the court had to stand back and apply totality to the aggregate. A disproportionate total required a significant downward adjustment.
2. Age was material to that assessment. The Sentencing Council guideline on sentencing young people applied. Turning 18 was not a cliff edge after which an ordinary adult sentence necessarily followed. Maturity was as important as chronological age. The pre-sentence report indicated some immaturity and susceptibility to peer influence. Academic ability did not necessarily demonstrate maturity. The fact that the appellant continued dealing while awaiting sentence could reflect immaturity or a calculated decision; it did not remove the need to assess his maturity.
3. Standing back, five years was manifestly excessive. The appropriate total was four years. The court reduced the first-indictment sentences from 20 to 14 months, concurrent, and the second-indictment sentences on counts 1 to 4 from 40 to 34 months, concurrent. The second-indictment terms remained consecutive to the first, producing 48 months overall.
4. Because the appellant was under 21 at the date of all the convictions, the custodial sentences technically had to take the form of detention in a young offender institution. The sentences were quashed and substituted accordingly. The reduction was not academic because it affected the licence period.

1. Court of Appeal (Criminal Division) — Allowed the appeal against sentence. The court quashed the concurrent sentences of 20 months and 40 months, substituted concurrent detention terms of 14 months and 34 months, and maintained consecutivity, resulting in a total of 48 months.
2. Crown Court at Maidstone — On 20 March 2026, Mr Recorder Passmore KC imposed concurrent sentences of 20 months on the first indictment and 40 months on the second, consecutive to each other, making five years’ custody overall.