R v Christopher Anjad Gifari
[2024] EWCA Crim 1419
Connor William Chapman v Rex
29 February 2024
[2024] EWCA Crim 190
Court of Appeal
Connor Chapman was given a life sentence with a minimum of 48 years in prison for killing Elle Edwards and injuring others in a gang shooting. The appeal court agreed the sentence was tough, but fair considering the extremely serious and planned nature of the crime and the multiple victims.
Key Facts
- •Connor Chapman (23) convicted of murder of Elle Edwards, attempted murder of Kieran Salkeld and Jake Duffy, wounding with intent, assault, and firearms offences.
- •Offences stemmed from gang violence on the Wirral.
- •Chapman sought revenge for an attack on a gang associate by shooting indiscriminately at a group outside a pub on Christmas Eve.
- •Elle Edwards was killed, and others seriously injured.
- •Chapman attempted to destroy evidence.
- •Judge sentenced Chapman to life imprisonment with a 48-year minimum term (less 176 days on remand).
- •Appeal argued the sentence was manifestly excessive and failed to adequately reflect Chapman's age.
Legal Principles
Whole life orders must be imposed under specific circumstances (Section 321, Sentencing Act 2020).
Sentencing Act 2020
Schedule 21, Sentencing Act 2020 provides starting points for minimum terms in murder cases, considering seriousness and aggravating/mitigating factors.
Schedule 21, Sentencing Act 2020
Sentencing for associated offences should reflect each offence but with consideration of totality (Attorney General's Reference (No 126 of 2010)).
Attorney General's Reference (No 126 of 2010)
Avoid double-counting aggravating factors when determining minimum term (R v Stanciu).
R v Stanciu [2022] EWCA Crim 1117
Comparisons with other cases are unhelpful in determining whether a sentence is manifestly excessive (R v Stewart and Others, R v Cashman).
R v Stewart and Others [2022] EWCA Crim 1063, R v Cashman [2023] EWCA Crim 1349
Outcomes
Appeal dismissed.
The Court found the 48-year minimum term, while severe, was not manifestly excessive given the exceptional seriousness of the offending, including the murder, attempted murders, and other offences. The judge's assessment was considered sound and the aggravating factors outweighed the mitigating factor of age.
Leave to appeal granted but appeal against sentence dismissed.
The court acknowledged the severity of the sentence but held that the judge appropriately considered the totality of the offending and that the sentence was not manifestly excessive in light of the circumstances.