Caselaw Digest
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Adam Royle & Ors v R

[2023] EWCA Crim 1311
Criminals who help the police get their sentences reduced. How much the sentence goes down depends on how much they helped and how dangerous it was for them to help. One criminal's appeal was rejected because the judge already gave him a fair reduction. Two other criminals got to stay secret for safety reasons.

Key Facts

  • Three applications for leave to appeal against sentence, two applicants (AJC and BCQ) remained anonymous due to risk of harm.
  • Adam Royle pleaded guilty to robbery and provided assistance to the police, his assistance being already public knowledge.
  • Applications raised issues relating to sentence reduction for offenders providing information and assistance to law enforcement.
  • Sentencing involved consideration of the Sentencing Code (Sentencing Act 2020) and Criminal Procedure Rules.
  • Cases involved both statutory and common law procedures for sentence reduction.

Legal Principles

Reduction in sentence for providing information and assistance to the police is a pragmatic convention to encourage cooperation and bring criminals to justice.

P and Blackburn

Reduction is justified whether information relates to the offence of conviction or other criminal activity, and whether provided before or after apprehension.

Sivan

Assistance must be provided before sentencing in the Crown Court; Court of Appeal reviews sentences, not conducts fresh sentencing.

A and B

Statutory procedure (ss74-75 and ss387-391 of Sentencing Code) involves a written agreement; common law procedure uses a 'text' from the police.

16, 17, 21

Sentence reduction should consider the starting point, aggravating/mitigating factors, reduction for assistance, and finally reduction for guilty plea.

26

Reduction amount varies depending on factors like quality/quantity of information, risk to informer, and assistance provided (e.g., giving evidence). Reduction between one-half and two-thirds is common, but not a standard.

King, P and Blackburn, A and B, Sivan, D, S, AAF

Sentencer's decision on reduction is reviewed only for errors of law, principle, or exceeding discretion.

S

General duty to explain sentencing reasons (s52, r25.16(7)(b)) doesn't require stating the exact reduction for assistance, except for guilty pleas.

35, 36, 37

Rule 28.1 (relating to explaining sentence reduction) applies only to the statutory procedure, not the text procedure.

41

Outcomes

Royle's appeal refused.

Judge's 11% reduction for assistance was within the acceptable range; assistance was modest, given in circumstances where both men sought to shift blame.

Decisions on AJC and BCQ's applications reserved for closed judgments.

Anonymity orders in place due to risk of harm.

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