R v Lavdrim Voka

When related offences are sentenced at different times, totality is assessed by comparing the practical effect of the later sentence with the sentence that might reasonably have been imposed if all offences had been dealt with together. The comparison must account for remand credit, time served, release assumptions, overlap between the offences and their distinct nature. Offences involving different classes of drugs may properly attract consecutive sentences where the offending is materially different. A sentence towards the upper limit is not manifestly excessive merely because totality requires a substantial discount.

The appellant pleaded guilty at the Crown Court at Worcester to two conspiracies to supply class A drugs and received a sentence of 15 years’ imprisonment. He had previously received a 10-year sentence at the Crown Court at Warwick for cannabis cultivation and related offending, including possession of cocaine with intent to supply.

He argued that the later sentence failed to reflect the totality of his offending and produced an equivalent sentence of 25 years. The central issue was whether the practical equivalent of the sentences, assessed as at the earlier sentencing date, was manifestly excessive.

1. Appeal dismissed. The 15-year sentence imposed at Worcester had not resulted in a sentence which was manifestly excessive. The publication prohibition made under section 4(2) of the Contempt of Court Act continued and applied to these proceedings in the same terms.
2. The correct totality approach was to assess the effect of the sentence actually imposed and compare it with the sentence that might reasonably have been imposed when all the offences were dealt with together. That required consideration of the practical release consequences, time already served and credit for time spent on remand.
3. The Worcester sentence began on 19 December 2024. By then the appellant had effectively served four years of the Warwick sentence, including remand credit. The later sentence extended the anticipated release date to June 2032. Calculated as if imposed in November 2022, that practical effect was equivalent to 23 years, not 25 years.
4. The court considered that the overlap between the offences was relatively small. Eight of the ten years imposed at Warwick related to cannabis cultivation, while the other Warwick offences had added only two years. Although both sets of offences involved unlawful drugs under the Misuse of Drugs Act, cannabis cultivation and conspiracy to supply class A drugs were different in nature. Given the scale of the Worcester offending, consecutive sentences were permissible.
5. The court endorsed 18 years as the appropriate sentence for the conspiracies. Only five additional years were required to produce the 23-year equivalent sentence. Although towards the upper limit, that aggregate sentence was not manifestly excessive.

• Court of Appeal (Criminal Division): [2026] EWCA Crim 211 dismissed the appeal against the 15-year sentence.
• Crown Court at Worcester: on 19 December 2024, HHJ Martin Jackson imposed 15 years’ imprisonment for two conspiracies to supply class A drugs.
• Crown Court at Warwick: in November 2022, the appellant received a total sentence of 10 years for separate drug-related offences. His appeal against that sentence was dismissed on 17 May 2023.