R v Colin Reeves
[2023] EWCA Crim 384
R v KGS
23 January 2024
[2024] EWCA Crim 85
Court of Appeal
A man killed two people because he disagreed with a court decision about his grandson. The judge gave him a 25-year sentence, but the appeals court increased it to 30 years because the crime was so serious—he planned the killings, used a gun, and his actions interfered with the justice system.
Key Facts
- •On March 29, 2023, the offender shot and killed JD and GD at point-blank range.
- •The killings were motivated by a Family Court decision regarding custody of the offender's grandson.
- •The offender pleaded guilty to two counts of murder.
- •The offender had a shotgun license and owned a shotgun.
- •The offender had made prior statements and sent text messages expressing violent thoughts.
- •The offender had taken photographs of the victims' homes and vehicles.
- •The offender's actions involved planning and premeditation.
Legal Principles
Mandatory life sentence for murder.
Sentencing Act 2020, s.321
Determining minimum term for murder, considering Schedule 21 of the Sentencing Act 2020 and relevant guidelines.
Sentencing Act 2020, Schedule 21
Schedule 21 starting points for minimum term based on offence seriousness (exceptionally high vs. particularly high).
Sentencing Act 2020, Schedule 21, paragraphs 2 & 3
Consideration of aggravating and mitigating factors in determining minimum term.
Sentencing Act 2020, Schedule 21, paragraphs 7-10
Reduction in sentence for guilty plea; maximum reduction is one-sixth of minimum term or five years.
Sentencing Council guidelines on reduction in sentence for a guilty plea
Application of Schedule 21 requires consideration of individual case facts; starting points provide a broad framework.
R v Jones [2005] EWCA Crim 3115
Attorney General not bound by prosecution concessions on sentencing categorisation, but bound by factual findings.
AG's reference (Stewart) [2016] EWCA Crim 2238
Mitigation for old age and ill-health considered, but harm and culpability remain primary factors.
R v Clarke [2017] EWCA Crim 393
Outcomes
Leave to refer the sentences granted.
The original sentence of 25 years was unduly lenient given the aggravating factors.
Minimum term increased to 30 years (less 206 days spent on remand).
The court found significant aggravating factors outweighing the mitigating factors, including the double murder, use of a firearm, premeditation, and interference with the course of justice.