Caselaw Digest
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R v Mark Walker & Ors

[2023] EWCA Crim 707
Someone tried to fix a drug dealer's trial by bribing a juror. The judge gave the guilty people prison time. The Attorney General thought the sentences were too light, but the Court of Appeal disagreed, saying the judge knew what he was doing and the sentences were fair.

Key Facts

  • Attorney General's application to refer sentences for conspiracy to pervert the course of justice and Juries Act 1974 offences.
  • Four defendants: Damien Drackley, Lorraine Frisby (Drackley's mother), Mark Walker, and Leslie Allen.
  • Allen's trial for drug offences (cocaine and cannabis supply) led to the conspiracy.
  • Conspiracy involved providing false evidence (Hayden, Porter) and jury manipulation (Drackley).
  • Drackley, a juror, contacted his mother (Frisby), who contacted Allen and Walker to orchestrate an acquittal.
  • Drackley attempted to influence fellow jurors, leading to the jury's discharge and Allen's conviction by the judge.
  • Sentences: Drackley (4 years), Frisby (2 years 3 months), Walker (9 months), Allen (5 years consecutive to his 13-year drug sentence).
  • Attorney General argued sentences were unduly lenient; defendants argued sentences were appropriate and considered all relevant factors.

Legal Principles

Offences of conspiracy to pervert the course of justice undermine the criminal justice system and are to be treated seriously, usually requiring immediate custody unless exceptional circumstances exist.

Court precedent and sentencing judge's remarks

Sentencing considers the seriousness of the substantive offence, persistence of conduct, and the attempt's effect.

R v Tunney [2006] EWCA Crim 2066 and R v Abdulwahab [2018] EWCA Crim 1399

Deterrence is an important factor in sentencing for conspiracy to pervert the course of justice, but a prison sentence itself is a substantial deterrent.

Judge's remarks and Court of Appeal's judgement

Outcomes

Leave to bring the Reference granted.

The case justified review.

Reference dismissed.

Sentences were not unduly lenient. The trial judge was best placed to consider the appropriate sentence, having considered all relevant factors, and no error of legal principle was found.

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