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R v Georgia Nicholson

[2023] EWCA Crim 1086
A young woman was given a too-light sentence for seriously hurting a taxi driver. The higher court looked at the crime, what the victim went through, and the young woman's situation and changed the sentence to 3 years in jail, instead of a suspended sentence.

Key Facts

  • Georgia Nicholson (born 7 December 2000) pleaded guilty to wounding with intent (s.18 Offences Against the Person Act 1861) on 13 February 2023.
  • The offence involved a group attack on a taxi driver, Mr Iftikhar, resulting in the loss of one of his eyes.
  • The incident occurred on 15 December 2018, when Nicholson was 18.
  • Nicholson was initially charged in October 2019, with significant delays in the proceedings.
  • The Crown Court at Warwick sentenced Nicholson to 24 months' custody suspended for 2 years, with 10 days of rehabilitation activity and £4000 compensation.
  • The Attorney General referred the sentence as unduly lenient.
  • Nicholson was pregnant at the time of sentencing and gave birth shortly after.

Legal Principles

Sentencing Guidelines for Causing Grievous Bodily Harm with Intent.

Sentencing Guidelines

Youth and immaturity are relevant considerations in sentencing young adults (18-25).

R v Clarke [2018] EWCA Crim 185

Sentencing should consider the impact on dependent children.

R v Petherick [2012] EWCA Crim 2214

Interests of an unborn child can be a factor in reducing a sentence.

R v Cheeseman [2020] EWCA Crim 794

Attorney General's power to refer sentences is unaffected by Goodyear indications.

Goodyear guidelines, paragraph 71

Court will not readily interfere with a judge's decision on whether to suspend a sentence unless plainly wrong.

R v Forest Jameson [2017] EWCA Crim 93

Outcomes

The Court of Appeal allowed the Attorney General's reference.

The original sentence was unduly lenient given the severity of the offence and the harm caused to the victim.

The Court imposed a sentence of 3 years' imprisonment.

This sentence considered the category 1 harm, culpability, aggravating factors (attack on a public service provider, alcohol involvement, group attack), and mitigating factors (age, lack of maturity, good character, delay, compensation, recent childbirth).

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