R v Rupert Earl-Ocran
[2024] EWCA Crim 1031
R v Connor Peter Crawford
10 May 2023
[2023] EWCA Crim 711
Court of Appeal
A man was found guilty of gun crimes. He appealed, saying the judge was unfair and his sentence was too long. The appeal court disagreed and said the evidence was strong enough and the sentence fair, but they removed an extra fee that was added wrongly.
Key Facts
- •Connor Peter Crawford pleaded guilty to possessing a prohibited firearm (Firearms Act 1968, s.5(1)(aba) - Count 2) and possessing a firearm when prohibited (s.21(1) - Count 4).
- •He was convicted of possessing a firearm with intent to endanger life (s.16) and possessing ammunition without a firearm certificate (s.1(1)(b) - Count 3).
- •Police stopped a car, Crawford exited with a handgun, discarded it, and was arrested.
- •The firearm was a 9mm Baikal pistol with live ammunition.
- •Crawford's defense was that he was under duress and unaware the pistol was loaded.
- •The prosecution presented witness statements, DNA evidence, and Crawford's silence during interview.
- •Crawford appealed his conviction and sentence, alleging issues with the judge's summing-up, evidence, solicitor/counsel conduct, and sentence length.
- •A surcharge order of £181 was added administratively to the sentence after the fact.
Legal Principles
Possession of a prohibited firearm
Firearms Act 1968, s.5(1)(aba)
Possession of a firearm when prohibited
Firearms Act 1968, s.21(1)
Possession of a firearm with intent to endanger life
Firearms Act 1968, s.16
Possession of ammunition without a firearm certificate
Firearms Act 1968, s.1(1)(b)
Criminal Justice Act 2003, s.161A - Surcharge Orders
Criminal Justice Act 2003, s.161A
Outcomes
Appeal against conviction refused.
The court found no arguable grounds for appeal; the evidence supported the conviction.
Appeal against sentence refused.
The sentence was deemed appropriate for the serious offenses and not manifestly excessive.
Surcharge order removed.
The £181 surcharge was added administratively after sentencing and was therefore unlawful.