R v Adam Robert Leddra

On a reference under section 36 of the Criminal Justice Act 1988, the court held that sentencing for multiple serious sexual offences must reflect the offender’s overall criminality. Short-duration grooming may justify category 1A culpability. Where four offences each had a five-year starting point, an increase to six years was inadequate. Serious aggravating features required a further uplift. Mitigation for relative youth, remorse, rehabilitation and good character was limited. Delay warrants no reduction unless shown to have caused detriment. Totality may require only a modest adjustment where comparable later offending has already been sentenced. A sentence materially below the least sentence properly imposable is unduly lenient and may be quashed and replaced.

Following guilty pleas, the offender was sentenced by the Crown Court at Newcastle upon Tyne for two offences under sections 9 and 10 of the Sexual Offences Act 2003, committed when he was 19 and the victim was 15. The Recorder treated the offences as category 1A and culpability A, increased a five-year starting point to six years for the four offences, and imposed 33 months’ imprisonment concurrently on each count after mitigation and credit for plea. The Attorney General referred the sentence as unduly lenient. The central issues were the proper treatment of grooming, multiple offences, aggravating and mitigating features, delay, totality and the offender’s previous sentence.

Reference allowed. The court granted leave under section 36 of the Criminal Justice Act 1988, quashed the sentence of 33 months’ imprisonment on each count, and substituted four years’ imprisonment on each count, to run concurrently.

1. Grooming and culpability. The Recorder was entitled to find clear grooming behaviour and to place each offence in category 1A. The conduct involved targeting and exploiting a young and vulnerable victim, including manipulative conduct directed towards obtaining sexual gratification. The fact that the grooming was not prolonged did not prevent that conclusion.
2. Multiple offences. The sentence had to reflect four separate offences committed over a significant period. Concurrent sentences were permissible, but the aggregate sentence had to reflect the overall criminality. An increase from the five-year starting point for one offence to six years for all four was significantly too small. The least justified increase was to eight years.
3. Aggravation and mitigation. Severe psychological harm, infection with an incurable disease and ejaculation inside the victim required a further minimum increase of one year, producing a notional sentence of nine years before mitigation. Relative youth justified some reduction, but no more than 15 per cent. Genuine remorse, rehabilitation and previous good character justified a maximum further overall reduction of 20 per cent, bringing the notional sentence to about six years.
4. Delay and totality. No reduction was justified for delay because detriment had not been shown, and the delay had allowed the offender’s reform to be demonstrated. After credit for plea, a sentence of about four and a half years was the least reasonable sentence for the present offending viewed alone. Applying totality in light of the previous 20-month sentence, a modest adjustment to four years was appropriate. The exercise was not strictly mathematical; the court stood back and assessed the least sentence that could properly be imposed.
5. The sentence of 33 months was materially below that minimum and was therefore unduly lenient. The court intervened because the discrepancy was substantial.

• Court of Appeal (Criminal Division) — On a reference under section 36 of the Criminal Justice Act 1988, the court granted leave, found the sentence unduly lenient, quashed it and substituted concurrent sentences of four years on each count: [2026] EWCA Crim 702.
• Crown Court at Newcastle upon Tyne — The Recorder imposed 33 months’ imprisonment concurrently on each of four counts following guilty pleas.