R v Jamie Worrall & Ors

Sentencing guidelines may justify sentences above the guideline ranges where a drug conspiracy operates on the most serious and commercial scale and involves quantities significantly exceeding category 1. Sentences of 20 years or more may then be appropriate, depending on the offender’s role. The relevant scale is that of the conspiracy as a whole, not merely the quantity personally handled by an offender. An appellate court should respect findings on quantity and role made by a trial judge who heard the evidence. Delay, pandemic conditions and prison overcrowding may be considered, but may carry limited weight where the sentence is long.

Four applicants were sentenced in the Crown Court at Worcester after pleading guilty to, or being convicted of, conspiracies to supply cocaine and cannabis. The judge found that the conspiracy as a whole involved 10 kilograms of cocaine and at least 20 kilograms of cannabis, and imposed sentences ranging from 17 to 23 years’ imprisonment. A single judge refused leave to appeal against sentence. The applicants renewed their applications, challenging the departure from the sentencing guidelines, the assessment of their roles and quantities, the treatment of previous convictions, mitigation, delay and prison conditions. The central issue was whether the sentences were wrong in principle or manifestly excessive.

The Court refused all four renewed applications for leave to appeal against sentence and adopted the single judge’s reasons.

1. Guideline departure. The common submission that the applicants could not properly be sentenced outside the guideline ranges was misconceived. The guidelines contemplate sentences of 20 years and above where an operation is on the most serious and commercial scale and involves quantities significantly higher than category 1, depending on the offender’s role. The finding of 10 kilograms of cocaine, together with at least 20 kilograms of cannabis, justified that approach.
2. Scale and the additional conspiracy. An offender’s personal quantity or basis of plea cannot displace the sentencing judge’s finding as to the scale of the conspiracy as a whole in which the offender participated. The court accepted the approach, reflected in R v Wilson [2024] EWCA Crim 124 and R v Chahal [2024] EWCA Crim 466, that a significant and adjacent Class B conspiracy could aggravate the sentence for a Class A conspiracy. The cannabis conspiracy therefore had to be reflected in the sentences.
3. Individual cases and review. Bailey’s delay, time on recall, pandemic circumstances and prison conditions were considered but properly given limited weight. His mitigation was also reflected in the absence of an uplift for previous convictions. Worrall’s cocaine starting point was not arguably wrong and his sentence was correctly calculated. The judge was well placed to assess Adams’s and Nicholls’s roles and the quantities involved, having heard the trial evidence. Their findings and the resulting sentences disclosed no arguable error or manifest excess.

The single judge was correct to refuse leave. The renewed applications were refused.

• Court of Appeal (Criminal Division): On 23 April 2026, the renewed applications for leave to appeal against sentence were refused. The court adopted the single judge’s reasons. [2026] EWCA Crim 632
• Crown Court at Worcester: His Honour Judge Burbidge KC sentenced the applicants following guilty pleas and convictions for conspiracies to supply cocaine and cannabis. The sentences ranged from 17 to 23 years’ imprisonment.