R v Nathaniel Armani

In sentencing for multiple offences, the totality principle requires the sentence to reflect the offender’s overall criminality, but does not require all terms to run concurrently. Separate offending may justify a consecutive term, while concurrent sentences may require an uplift in the sentence for the principal offence. The court must assess the offending globally, including its scale and duration, before deciding whether the aggregate sentence is manifestly excessive. Guilty plea credit depends on the factual basis ultimately accepted; an early plea on a materially narrower basis does not necessarily attract the maximum reduction. Sentencing remarks must be read as a whole and in context.

The appellant pleaded guilty in the Cardiff Magistrates’ Court to drug-supply and money-laundering offences. On 2 May 2025, the Crown Court at Merthyr Tydfil imposed an aggregate sentence of 15 years’ imprisonment for prolonged and large-scale drug offending, associated money laundering and possession of criminal property. The appellant challenged the sentence, arguing that the starting point for the cocaine offence was excessive, that he was entitled to 33 per cent credit for his pleas, that insufficient weight had been given to mitigation, and that the sentences should run concurrently. The single judge refused leave. The renewed application concerned whether the sentence was wrong in principle or manifestly excessive.

1. The renewed application for leave to appeal against sentence was refused. The court entirely agreed with the single judge’s reasons that the sentence was neither wrong in principle nor excessive.

2. The totality principle required the court to consider the appellant’s offending globally. It did not require every sentence to be concurrent. The separate section 329 offence committed on 12 October 2023 could properly attract an 18-month consecutive term. Conversely, if that term had been concurrent, the sentence for the cocaine offence would have needed to be higher to reflect the same overall criminality.

3. The money-laundering offending under sections 327 and 329 of the Proceeds of Crime Act 2002, together with the cannabis offence, justified a substantial uplift in the sentence for the cocaine offence considered in isolation. The sustained offending, the quantities of drugs and cash, and the appellant’s significant role in an organised crime group meant that the proportionate sentence before mitigation and plea credit would have been significantly above 20 years. A final sentence of 15 years was therefore not manifestly excessive.

4. The sentencing remarks had to be read in context. The reference to an 18-year sentence after trial for the cocaine offence plainly included the uplift associated with the concurrent sentences imposed immediately afterwards. It was not a standalone sentence calculated solely by reference to the quantity of cocaine.

5. The appellant’s initial guilty plea had been advanced on the basis of involvement with only 1 kilogram of cocaine. Following an adjourned Newton hearing, he accepted involvement with 11 kilograms. In those circumstances, the 25 per cent reduction reflected the factual basis ultimately accepted, notwithstanding that the plea had been entered in the magistrates’ court. The judge had also taken the psychiatric evidence and other mitigation into account.

• Court of Appeal (Criminal Division): In [2026] EWCA Crim 322, the renewed application for leave to appeal against sentence was refused.
• Single judge: Refused leave to appeal against sentence.
• Crown Court at Merthyr Tydfil: On 2 May 2025, imposed an aggregate sentence of 15 years’ imprisonment.
• Cardiff Magistrates’ Court: The appellant entered guilty pleas to the relevant offences in October and December 2023.