R v Abdul Raheem Howe
[2024] EWCA Crim 1224
R v Leon Alexander
6 June 2024
[2024] EWCA Crim 705
Court of Appeal
A man was convicted of several serious sexual assaults. He appealed, arguing the judge made mistakes. The appeals court disagreed, saying the evidence was fair and the sentence was deserved because he's dangerous. The man will serve a long prison sentence.
Key Facts
- •Leon Alexander (applicant) convicted of four counts: rape, sexual assault, and causing/inciting a child to engage in sexual activity.
- •Offenses against three complainants (C1, C2, C3) spanning from 2010 to 2022.
- •Applicant received an extended sentence of 17 years (14 years custodial, 3 years extension) for oral rape of C1 (Count 5), with concurrent sentences for other counts.
- •Appeal against conviction and sentence was refused by a single judge and subsequently by the Court of Appeal.
- •Bad character evidence, including previous convictions for exposure and a rape acquittal, was admitted.
Legal Principles
Reporting restrictions under the Sexual Offences (Amendment) Act 1992 apply to protect victim identity.
Sexual Offences (Amendment) Act 1992
Admissibility of bad character evidence under the Criminal Justice Act 2003.
Criminal Justice Act 2003
Test for dangerousness under Schedule 18 of the Sentencing Act 2020 for extended sentences.
Sentencing Act 2020
Sentencing guidelines for sexual offences.
Sexual Offences Guidelines
Outcomes
Appeal against conviction refused.
Court of Appeal found no merit in any of the grounds of appeal against conviction, agreeing with the single judge's assessment. The bad character evidence was deemed admissible, and procedural issues were not considered grounds for overturning the conviction.
Appeal against sentence refused.
The Court of Appeal upheld the extended sentence, finding it justified by the applicant's dangerousness and the severity of the offences. The length of the sentence was deemed proportionate.
Statutory surcharge quashed.
The surcharge order was unlawful due to the age of the offences (pre-2007 Order).