R v Ansreen Buhari

For an out-of-time challenge to sentence, a disparity with a co-offender does not by itself justify reopening the sentence. The court must consider why the co-offender’s sentence changed and whether the sentencing judge identified the correct statutory starting point and made an individual assessment of culpability. A reduction based on a co-offender’s youth or immaturity does not show that an adult co-offender’s sentence was subject to unjustified upward pressure. Mitigation arising from a victim’s conduct may carry limited weight where the offender had opportunities to prevent escalation but participated in it. The trial judge’s first-hand assessment of the facts and relative culpability is relevant. The application for an extension of time and leave to appeal was refused.

After a trial at Leicester Crown Court, the applicant was convicted of two murders arising from a high-speed pursuit that ended in a fatal collision. On 1 September 2023, she received life imprisonment with a minimum term of 26 years and nine months. Her application for an extension of time was 780 days late. She relied on the later reduction of her daughter’s minimum term in [2025] EWCA Crim 1353, arguing that the disparity indicated error and that the sentencing judge had given insufficient weight to blackmail, her lesser role in planning, and other mitigation. The central issues were whether time should be extended and whether the proposed grounds disclosed an arguable error or a manifestly excessive minimum term.

The court refused both the application for a 780-day extension of time and the application for leave to appeal against sentence.

1. Effect of the related appeal. The reduction of the co-offender’s minimum term in [2025] EWCA Crim 1353 resulted from the sentencing judge’s failure to give sufficient weight to that offender’s youth and immaturity. That reasoning did not assist an offender aged 45. The fact that the applicant’s term was only one year below her daughter’s neither explained the delay nor demonstrated error in the applicant’s sentence.
2. Sentencing exercise. Section 321 of the Sentencing Act 2020, together with paragraph 3 of Schedule 21, provided the undisputed 30-year starting point for the murder of two persons. The sentencing judge then assessed aggravating and mitigating factors individually for each offender. The court rejected the suggestion that the co-offender’s age-related reduction had created unjustified upward pressure on the applicant’s term.
3. Mitigation. The trial judge was particularly well placed to assess the factual circumstances and relative culpability. He had considered the background of blackmail. The applicant had nevertheless had opportunities to prevent the escalation, so any mitigation arising from the deceased’s conduct was limited and had been adequately reflected. Her lesser involvement in planning had already been recognised. Her post-incident demeanour, viewed with her conduct and attitude, did not establish significant remorse.
4. Overall assessment. Having stood back and considered all matters advanced, the court concluded that the applicant’s minimum term properly reflected her central role and the relevant aggravating and mitigating circumstances. There was no sufficient basis to extend time or grant leave.

• Court of Appeal (Criminal Division): On 3 July 2026, the court refused the applicant’s application for a 780-day extension of time and for leave to appeal against sentence.
• Crown Court at Leicester: Following conviction for two murders on 4 August 2023, the applicant was sentenced on 1 September 2023 to life imprisonment with a minimum term of 26 years and nine months.