R v Raymond Martin Langley

When sentencing historic sexual offences, the court must respect the statutory maximum in force when the offences were committed while having regard to sentencing guidelines in force at the date of sentence. It may select a modern equivalent offence where the elements correspond. The rape guideline is appropriate where historic buggery amounted to anal rape; the sexual-activity-with-a-child guideline is inappropriate where it does not reflect the seriousness of the conduct. A guideline starting point may be increased substantially for multiple offences and aggravating features. Totality may require concurrent terms for offending against each victim and consecutive terms between victims. Age, ill health, personal history, passage of time and good character must be considered, although previous good character may carry limited weight in historic sexual-offence cases.

The appellant was convicted at Lewes Crown Court of four counts of buggery and 12 counts of indecent assault arising from historic sexual abuse of two boys at a boarding school. The offences were committed between 1977 and 1979, when the complainants were aged between 12 and 14.

The Recorder used the modern rape guideline for the four buggery counts, treated one count against each complainant as the lead offence, and imposed a total sentence of 20 years’ imprisonment after applying totality. The appellant appealed by leave, arguing that the guideline for sexual activity with a child should have been used for most counts, that the guidelines had been applied mechanistically, and that insufficient weight had been given to his age, health, good character and the passage of time. The central issue was whether the sentence was manifestly excessive.

Appeal dismissed. The 20-year sentence was lawful, proportionate and not manifestly excessive.

1. For historic offences, the sentencing court must sentence against the statutory maximum applicable when the offence was committed, while having regard to the guidelines in force at the date of sentence. It may identify a modern offence containing equivalent elements as the appropriate guideline.
2. The offences against the two complainants amounted to anal rape. The rape guideline under section 1 of the Sexual Offences Act 2003 was therefore appropriate. The guideline for sexual activity with a child under section 9 was not appropriate because sexual touching under that provision does not necessarily amount to rape and did not reflect the seriousness of the offending.
3. The Recorder correctly used category 2A rape offences, with a starting point of 10 years and a range of nine to 13 years. She was entitled to increase the starting point substantially to reflect the two anal rapes against each complainant and the multiple associated sexual assaults. This was not a mechanistic application of the guideline or the selection of the top of the range.
4. The conventional totality approach was correctly applied. The most serious offence against each complainant was treated as the index offence, a term was assessed for the overall criminality against that complainant, the terms were reduced for totality, other offences against the same complainant attracted concurrent terms, and the terms for the two complainants were consecutive.
5. The specific targeting of vulnerable boys and the multiple offences were aggravating features. The Recorder expressly considered the appellant’s age, health, abusive childhood, the passage of time, his wife’s death and character references. In historic sexual-offence cases, previous good character carries limited weight, particularly where the victims’ trauma has continued for decades.

• Court of Appeal (Criminal Division): In [2026] EWCA Crim 449, the appeal against sentence was dismissed.
• Crown Court at Lewes: The appellant was convicted on four counts of buggery and 12 counts of indecent assault and sentenced to 20 years’ imprisonment.