R v Jawaad Tariq

A sentencing court must specify the credit period to which an offender is entitled for time spent on bail subject to a qualifying curfew and electronic monitoring. An omission may be corrected on appeal. Where the offender bears no responsibility for the omission, and delay results from a proper attempt to obtain correction under the slip rule which cannot be completed within the statutory deadline, the appellate court may extend time and grant leave. The correction may be confined to specifying the credit period, leaving the sentences otherwise unaffected.

Jawaad Tariq was sentenced at Manchester Crown Court to two months’ imprisonment for driving whilst disqualified and eight months’ imprisonment, consecutively, for perverting the course of justice. The Recorder also imposed a driving disqualification of three years and eight months.

Before trial, Tariq had spent 18 days on bail subject to a qualifying curfew and electronic monitoring. The parties agreed that he was entitled to nine days’ credit. Neither party drew the curfew to the Recorder’s attention, and the Recorder omitted to specify the credit period. An attempt to correct the sentence under the slip rule could not be dealt with within the statutory 56-day deadline. The Registrar referred Tariq’s application for a 32-day extension of time and leave to appeal to the full court. The sole issue was correction of the omitted credit.

1. The court granted an extension of time of 32 days, gave leave to appeal and allowed the appeal solely to specify a credit period of nine days. The custodial sentences and the other sentencing orders were otherwise unaffected (paras [1], [5]).

2. The applicant’s qualifying curfew and electronic monitoring conditions had operated for 18 days. It was agreed that those conditions entitled him to nine days’ credit under section 240 A of the Criminal Justice Act 2003. Section 325(2) of the Sentencing Act 2020 required the Recorder to specify that credit period. The failure to do so resulted from neither party drawing the qualifying curfew to the Recorder’s attention. The Recorder was therefore without fault, and the applicant could not be held responsible for the omission (paras [3]–[4]).

3. Having considered R v Thorsby and others [2015] EWCA Crim 1 and R v Marshall and others [2015] EWCA Crim 1 999, the court was willing to correct the position. The delay was explained by the applicant’s proper attempt to obtain correction under the slip rule. The Crown Court had been unable to deal with that attempt within the 56-day deadline under section 385(2) of the Sentencing Act 2020. Those circumstances justified the extension of time and the limited appellate correction (paras [4]–[5]).

• Court of Appeal (Criminal Division): In [2026] EWCA Crim 1285 , following referral by the Registrar, granted a 32-day extension of time and leave to appeal. Allowed the appeal solely to specify nine days’ credit under section 325(2) of the Sentencing Act 2020. The sentences were otherwise unaffected.
• Manchester Crown Court: On 13 July 2026, Mr Recorder Gurney KC imposed consecutive custodial sentences of two months and eight months, together with a driving disqualification of three years and eight months. The qualifying-curfew credit period was omitted. A subsequent attempt at correction under the slip rule could not be dealt with within the statutory 56-day deadline.