Police Gang Officers as Expert Witnesses and Youth Sentencing in Serious Gang Violence: Commentary on R v Edokpolo & Alexander [2025] EWCA Crim 1534

1. Introduction

This commentary examines the decision of the England and Wales Court of Appeal (Criminal Division) in R v Edokpolo & Alexander [2025] EWCA Crim 1534, a judgment that sits at the intersection of three contemporary issues in criminal law:

The admissibility and scope of police “gang expert” evidence in serious violence trials, and its treatment as expert opinion under Myers v The Queen [2015] UKPC 40; [2016] AC 314.
The use of gang association and prior misconduct as bad character evidence under the Criminal Justice Act 2003.
The sentencing of children and young people involved in extreme gun and gang-related violence, including:
- parity and disparity in joint enterprise attempted murder; and
- very long minimum terms for detention during His Majesty’s Pleasure following murder and multiple attempted murders by a 16‑year‑old.

The decision concerns:

Marvin Edokpolo – aged 17 at the time of the offence – convicted of the attempted murder of Hakeemm Malone at Hackney Central station on 1 March 2023, and sentenced to 22 years 3 months detention in a Young Offender Institution.
Joshua Alexander – aged 16 at the time of the relevant offences – a co‑defendant in the same attempted murder; later convicted of:
- the murder of Lianne Gordon, an entirely innocent victim killed in her own home;
- two further counts of attempted murder;
- firearms and bladed article offences; and
- drug supply offences.
He received detention during His Majesty’s Pleasure with a minimum term of 28 years and 8 days.

The Court (constituted as the Court of Appeal (Criminal Division)) refused:

Edokpolo’s renewed application for leave to appeal against conviction;
dismissed his appeal against sentence (having granted leave on disparity); and
dismissed Alexander’s appeal against sentence.

The judgment is important for its confirmation that relatively junior police gang officers can be accepted as expert witnesses when their experience is sufficiently focused, and for its firm line on exceptionally severe sentences for gang-related homicide by children, even where there is evidence of vulnerability, trafficking and developmental difficulties.

2. Summary of the Judgment

2.1 Factual background

2.1.1 The Hackney Central attempted murder (1 March 2023)

On 1 March 2023, during a period of tit‑for‑tat violence between the Hackney‑based London Fields and Pembury (E9/E98) gangs:

Victim Hakeemm Malone travelled by train from Stratford to Hackney Central.
Joshua Alexander was on the same train and communicated by phone with Marvin Edokpolo during the journey.
On leaving the train, Malone headed toward the station lifts.
Three others – Hanzell Greenaway, Jaheim Thomas and Elisandro Pinto‑Alves – cycled at speed from a McDonald’s in Mare Street after receiving a call. There was contemporaneous Snapchat and telephone communication between Greenaway and Edokpolo.
The group forced their way through station barriers and found Malone at the lifts.
Greenaway stabbed Malone; Thomas shot him; Pinto‑Alves attempted to stab him.

Malone suffered:

three penetrating chest wounds (including a stab wound penetrating the heart);
a wound to the arm; and
a gunshot wound to the leg.

Only prompt advanced medical intervention (HEMS) prevented death.

The prosecution case – accepted by the jury and the sentencing judge – was that:

this was a joint, targeted, gang‑motivated attack rooted in the London Fields/Pembury rivalry;
Alexander provided real‑time information from the train;
Edokpolo co‑ordinated with Greenaway and others, passing on that “the hit was on,” enabling them to locate and attempt to kill Malone.

2.1.2 Alexander’s later offending (December 2023)

After being bailed for the attempted murder, subject to conditions including not entering Hackney, Alexander:

returned daily to a “gang hub” at 8 Bodney Road, involved in Class A drug supply;
re‑entered Hackney, breaching bail, and on 2 December 2023:
- cycled to Vine Close in rival gang territory with a firearm and machete;
- test‑fired the gun in a park, recording it;
- discharged the gun four times at Vine Close (no injuries on that date).
on 5 December 2023, returned alone to Vine Close with the same gun, intending to kill rival gang members:
- shot at two men (Raheem Tan‑Ming and Amani Adams‑Maguire) outside the address, injuring them;
- fired through the front door of the property, fatally wounding Lianne Gordon, a 42‑year‑old mother of two, who was not the intended target and was inside her own home.

In total he fired the weapon eight times on 5 December. He was arrested on 8 December 2023; Class A drugs were found at his home. He was later convicted of murder, two attempted murders, firearms offences, a bladed article offence, affray, and drug supply, and sentenced to detention during His Majesty’s Pleasure with a 29‑year minimum term (less time on remand, making 28 years 8 days).

2.2 Edokpolo’s conviction appeal

Edokpolo renewed his application for leave to appeal conviction on three principal grounds:

Gang expert evidence – that the evidence of PC Wright of the Hackney Integrated Gangs Unit did not meet the standard for expert evidence under Myers v The Queen, and should have been excluded.
Specific bad character evidence – that evidence of a prior caution/conviction (involving banging on a door and a threat that someone might be “shanked”) had negligible probative value and should have been excluded under the Criminal Justice Act 2003 or under PACE s.78.
Summing‑up comment – that the trial judge’s remark about lack of evidence on whether Snapchat and a telephone call can operate simultaneously misrepresented and undermined a central defence argument.

The Court rejected all three grounds and refused leave:

It upheld the trial judge’s finding that PC Wright was capable of giving expert evidence on local gangs and rivalry, and that the gang evidence was admissible as:
- “to do with the facts of the offence” for the purposes of s.98 CJA 2003 (motive); and
- relevant to an important issue (“innocent association”) under s.101(1)(d) CJA 2003.
It held that the prior incident/caution properly passed through the same gateways, showing his association with gang members, and that its admission did not render the trial unfair.
It considered the Snapchat comment unobjectionable when read in full and in context, and not capable of rendering the conviction unsafe.

2.3 Edokpolo’s sentence appeal

The sentencing judge categorised the attempted murder as:

very high culpability (planned use of a firearm);
Category 2 harm (very serious injury but not in the most serious band).

For an adult, the relevant guideline starting point was 30 years’ imprisonment (range 25–35). Key aggravating features included:

sophisticated planning;
gang motivation;
a public attack in the middle of the day;
use of a member of the public as a human shield by the victim;
relevant previous convictions for Edokpolo (unlike his co‑defendants).

Co‑defendants’ sentences:

Thomas: 19 years;
Greenaway: 19 years;
Pinto‑Alves: 17 years;
Edokpolo: 22 years 3 months.

The judge stated she saw “little difference … in terms of culpability” between the four, yet imposed the highest sentence on Edokpolo. On appeal:

The Court accepted that the argument on disparity was arguable and granted leave.
However, it held that, given:
- the trial judge’s superior vantage point after a three‑month trial;
- Edokpolo’s key co‑ordinating role in the attack;
- his previous convictions; and
- his being slightly older than the others;
the sentence, though severe, was not manifestly excessive. The appeal against sentence was dismissed.

2.4 Alexander’s sentence appeal

The judge, applying the murder guideline for children and young people and the overarching youth sentencing guideline, adopted:

a 20‑year starting point for the murder (for Alexander’s age of 16 years 10 months), noting that:
- had he been an adult, the starting point would have been 30 years; and
- had he been 17, 27 years.
found culpability “particularly high” given planning, gang motivation, use of a gun to fire through a front door, and the fact the victim was at home behind her own door, and that he was on bail.
indicated that, for the murder standing alone, she would impose a 24‑year minimum term (20‑year starting point plus a 4‑year uplift for aggravation).
then adjusted for the totality of the remaining serious offences (two attempted murders, firearms, bladed article, affray, and drug supply) to reach an overall 29‑year minimum term (28 years 8 days after deducting remand time).

On appeal, Alexander relied principally on:

his age (16 years 10 months at the time);
an IQ of 75, above‑average suggestibility and extremely poor recall (per Dr Conning);
evidence (from Mr Carswell) that he had been a victim of human trafficking and modern slavery, kidnapped and threatened in 2022 and drawn into gang activity.

The Court:

accepted that his developmental age did not match his chronological age, and that he had been exploited and vulnerable;
nonetheless emphasised that he had made a conscious decision to join the gang, to return to the gang hub despite supportive interventions, and to engage in repeated, extreme violence for status;
having regard to the overall offending (three attempted murders and one murder, alongside serious firearms and drug dealing), concluded it was “impossible to say” that a minimum term of 28 years 8 days was manifestly excessive.

The appeal against sentence was therefore dismissed.

Finally, in light of Alexander’s developmental difficulties, the Court extended legal aid to cover his solicitor’s attendance at the appeal hearing and post‑hearing communication, and recorded judicial commendations for the police investigation.

3. Detailed Analysis

3.1 Police gang officers as expert witnesses

3.1.1 The legal issue

The first major issue concerned the status and admissibility of “gang evidence” in serious youth violence trials. The prosecution case relied heavily on:

background evidence about gang rivalries, recruitment, hierarchy, territory, and prior violent incidents;
evidence of the affiliations of the defendants to particular gangs (notably Pembury and London Fields);
evidence targeted at showing that Edokpolo was a committed member of the Pembury gang.

The defence argued that the main gang witness, PC Wright of the Hackney Integrated Gangs Unit:

was not an “expert” in the sense required by Myers v The Queen and by the Criminal Procedure Rules;
had no personal dealings with Edokpolo;
had no specific training as a gang expert; and
had only under three years’ experience in the gang unit.

It was also argued that his statements initially contained “bald assertions” and lacked proper evidential support.

3.1.2 Myers v The Queen and expert evidence

In Myers v The Queen [2015] UKPC 40; [2016] AC 314, the Privy Council examined the scope of expert evidence in gang cases. The key principles derived from Myers include:

Expert evidence is admissible where it concerns matters outside the knowledge of the lay jury and will assist them in understanding the issues.
A witness can gain expertise through practical, experience‑based knowledge as well as academic or formal training.
The expert must:
- properly identify the material on which their opinions are based;
- explain the methodology and limitations of their opinion;
- avoid mere assertions unconnected to an evidential foundation.

Myers thus does not require lengthy formal qualifications, but demands that any claimed expertise be demonstrably reliable and transparent.

3.1.3 Application to PC Wright’s evidence

The trial judge had scrutinised PC Wright’s statements, required further detail where assertions were unsupported, and then ruled that:

Wright had sufficient expertise – based on his experience in the Hackney Integrated Gangs Unit – to give expert evidence about:
- the rivalries between London Fields and Pembury gangs; and
- the nature of local gang structures and activities.
He could offer an opinion on whether Edokpolo was associated with the Pembury gang, though subject to robust cross‑examination.
The evidence was relevant to:
- motive for the attack on Malone; and
- the issue whether communication between the defendants was innocent or incriminatory (gateway under s.101(1)(d) CJA 2003).

The Court of Appeal upheld this approach:

It accepted that, even with less than three years’ specific experience and no formalised “expert” title, Wright had sufficient specialised knowledge of Hackney gangs to assist the jury.
It stressed that any deficiencies in his evidence could be probed in cross‑examination and through judicial directions limiting its use.

Crucially, the Court rejected the invitation to treat this case as materially different from previous gang‑evidence cases in a way that would render admission improper. It described the gang‑association evidence as admissible and properly left to the jury.

3.1.4 Significance

This aspect of the judgment has several effects:

Threshold for police gang “experts”: It confirms that a relatively junior police officer, without formal specialist qualifications but with focused, local experience in a gang unit, may properly be treated as an expert. The practical emphasis is on experience and knowledge of the area and its gangs, not on titles or years of service alone.
Judicial gatekeeping: The trial judge’s task is to:
- interrogate and refine the expert’s statement;
- ensure that bare assertions are supported or clarified;
- define clearly the limits of the expert’s expertise;
- and then allow the defence to challenge the opinions before the jury.
The Court of Appeal is slow to interfere with that evaluative exercise unless plainly wrong.
Use of gang evidence: The Court stresses the limited, targeted purposes for which gang evidence may be used (motive and rebuttal of innocent association), and that juries can be trusted to follow such directions.

For future cases, this judgment will be cited to support the proposition that: “A police officer with sufficiently focused experience in a local gang unit can be treated as an expert whose opinions about gang rivalry and association are admissible, provided their evidential basis and limitations are properly identified and controlled.”

3.2 Bad character, gang association and fairness

3.2.1 Statutory framework

Three provisions are central:

Criminal Justice Act 2003, s.98 – defines “bad character” but excludes evidence which is:
“to do with the alleged facts of the offence with which the defendant is charged, or to do with the investigation or prosecution of that offence.”
If evidence is “to do with the facts”, it is treated as not bad character at all.
Criminal Justice Act 2003, s.101(1)(d) – one of the “gateways” allowing admission of defendants’ bad character where it is:
“relevant to an important matter in issue between the defendant and the prosecution.”
Here, the important matter in issue was whether the defendants’ communications and associations were innocent.
Criminal Justice Act 2003, s.101(3) and Police and Criminal Evidence Act 1984, s.78 – allow the court to exclude evidence, even if technically admissible, where its admission would have such an adverse effect on the fairness of proceedings that it ought not to be admitted.

3.2.2 The prior caution/conviction as gang evidence

The contentious evidence, admitted by agreement as a fact, was that:

on an earlier occasion, Edokpolo had been arrested after banging on a door of a victim who was said to be at risk of being “shanked”;
he was in company with other individuals, alleged gang members;
this led to a caution/conviction.

The defence argued this episode:

had little true probative value as to gang membership or motive;
might simply show him succumbing to peer pressure on the day;
was unfairly prejudicial, inviting the jury to reason “once violent, always violent.”

The Court held, however, that:

the incident constituted evidence of:
- association with known gang members; and
- participation in a potentially gang‑related confrontation;
this made it relevant to the alleged gang‑motive and to the issue of whether his associations with co‑defendants in the present case were truly innocuous;
the evidence therefore passed through the s.98/s.101(1)(d) gateways;
its admission did not have such an adverse effect on fairness as to trigger exclusion under s.78 PACE or s.101(3) CJA 2003, especially as:
- it was only one strand in a wider evidential picture; and
- there was no suggestion the jury might convict wholly or mainly on its basis.

3.2.3 Fairness and proportionality

This part of the judgment illustrates the approach to balancing:

the real probative value of limited prior incidents in showing gang association or motive; against
the risk of unfair stigma and propensity reasoning (“gang member = guilty”).

The Court’s stance is relatively robust: where prior conduct genuinely illuminates gang context or associations that bear on motive and the nature of communication between co‑defendants, it is likely to be held admissible. Exclusion will generally require a clearer showing that the probative value is marginal and prejudicial effect substantial.

3.3 Judicial comment and the safety of the conviction

The third conviction ground focused on a short passage in the judge’s summing‑up:

“I am not saying disregard his points, but I am simply saying that there is no evidence about whether you can or not – contiguously, I think is the word – have a Snapchat call at the same time as a telephone voice call…”

The defence submission was that this mischaracterised or devalued a key argument: that if Edokpolo were already in a call with Greenaway, there was no common‑sense reason why he would make another concurrent call, thus supporting the idea that he was not co‑ordinating an attack.

The Court’s reasoning is instructive:

Judges are entitled to remind juries that they must decide cases on the evidence, not on speculation about technical matters (here, the functionality of Snapchat and phone calls).
The judge explicitly said she was not inviting the jury to disregard the defence’s common‑sense point.
Read in context of the full summing‑up, and against the backdrop of detailed directions on the defence case, the comment did not undermine the fairness of the trial.

The Court reiterated the high threshold for appellate interference in summing‑up complaints: an appellate court will not readily find an “unsafe” conviction from brief remarks unless they significantly misrepresent the defence case or improperly usurp the jury’s function. Here, that threshold was far from met.

3.4 Sentencing a young co‑ordinator in a joint enterprise attempted murder: Edokpolo

3.4.1 Guideline framework

The sentencing judge categorised the attempted murder as:

Very high culpability – planned use of a prohibited firearm in a public place; and
Category 2 harm – very serious, life‑threatening injuries but not in the most extreme band (e.g. permanent vegetative state, multiple victims, etc.).

Under the Attempted Murder Sentencing Guideline (for adults), that yields a 30‑year starting point, range 25–35 years. For youths, the court must then:

apply appropriate reductions to reflect age and maturity; and
have regard to the Overarching Guideline: Sentencing Children and Young People.

3.4.2 Role, parity and disparity

The key sentencing complaint was disparity between the four co‑defendants:

Thomas and Greenaway: 19 years;
Pinto‑Alves: 17 years;
Edokpolo: 22 years 3 months;
Yet the judge described there as being “little difference … in terms of culpability.”

The Court’s response encapsulates the modern law on disparity:

Sentencing judge’s vantage point: The judge presided over a three‑month trial, observed the witnesses, and was uniquely placed to assess relative roles. Appellate courts are slow to disturb such evaluations.
Distinct aggravation for the organiser: The Court stressed that:
- Edokpolo played an “important co‑ordinating role” – acting as the conduit of information, effectively signalling that “the hit was on.”
- Organisers or facilitators may properly receive more severe sentences than those physically present, especially in gang attacks, even if they wielded no weapon and were not at the scene.
Personal aggravating factors: Unlike his co‑defendants, Edokpolo had:
- relevant previous convictions; and
- was slightly older, albeit not by a wide margin.
These factors justified a higher sentence despite apparently similar culpability at the scene.
High bar for disparity appeals: The Court reiterated that a disparity challenge rarely succeeds. The test is not whether another judge might have passed a lower sentence, but whether the sentence is manifestly excessive or wrong in principle in light of the co‑defendants’ sentences. Here, it was “severe, but not manifestly excessive.”

The decision underscores a significant point: even where a judge describes culpability as similar, a defendant who is the older, previously convicted, off‑scene co‑ordinator may receive a materially higher sentence without amounting to unjust disparity.

3.5 Sentencing a child gang member for murder and multiple attempted murders: Alexander

3.5.1 Detention during His Majesty’s Pleasure and minimum terms

For murder committed by a person under 18, the court must impose detention during His Majesty’s Pleasure (DHMP) – an indeterminate sentence. The judge then sets a minimum term which must be served before the offender can be considered for release by the Parole Board. The minimum term is based on:

statutory starting points in the murder guideline for youth offenders;
aggravating and mitigating factors; and
the totality of all offences.

Here:

Alexander’s age (16 years 10 months) yielded a 20‑year starting point for the murder alone.
Taking account of particularly high culpability, the judge applied a 4‑year uplift, reaching 24 years for the murder alone.
To reflect the gravity of:
- two additional attempted murders;
- a firearms offence with intent to endanger life;
- a bladed article offence;
- affray; and
- class A drug supply;
the judge increased the minimum term to 29 years (less time on remand: 28 years 8 days).

3.5.2 Aggravating features and the 4‑year uplift

The Court carefully examined whether a 4‑year uplift from the 20‑year starting point was excessive. It endorsed the judge’s view of the aggravating factors:

Significant planning – repeated visits to rival territory armed with a gun and machete, and test‑firing the weapon.
Gang motivation – part of an ongoing turf war.
Victim in her own home – Ms Gordon was behind her front door, an especially grave breach of the expectation of safety in one’s home.
Offending on bail – he was still on bail for the earlier attempted murder of Malone.
Weapon unrecovered – ongoing risk to the public.
Multiplicity of victims – two injured intended targets plus one fatal innocent victim.

The Court held that in these circumstances, the uplift from 20 to 24 years for the murder alone was justifiable.

3.5.3 Vulnerability, trafficking and developmental factors

Perhaps the most sensitive part of the judgment concerns the treatment of:

Alexander’s cognitive and psychological profile (IQ 75, high suggestibility, very poor recall);
his status as a victim of trafficking and modern slavery, including kidnapping and threats;
his history of gang exploitation.

The Court explicitly acknowledged:

that his developmental age was below his chronological age;
that he had been lured into gang life by the promise of money and “female company”; and
that he had suffered “wretched” experiences.

However, the Court placed significant weight on agency and choice:

Despite support, he repeatedly rejected attempts by his parents and others to help him leave the gang environment.
He returned daily to the gang hub at Bodney Road.
He chose to participate in very serious violence, apparently to seek status within the gang.

The Court’s reasoning signals that:

While trafficking, exploitation and cognitive deficits are powerful mitigating factors in youth sentencing, they will not automatically or necessarily prevent the imposition of extremely long minimum terms where the offending is exceptionally grave, persistent, and reflects sustained, conscious choices.

This approach follows the youth sentencing guideline’s emphasis on:

recognising reduced culpability due to age and vulnerability; but
also acknowledging personal responsibility and protection of the public in cases of extreme violence.

3.5.4 Totality and proportionality

The Court “stepped back” and examined whether the overall sentence of 28 years 8 days:

was proportionate to the totality of offending; and
was consistent with sentences for adults and for near‑17‑year‑olds.

Given that:

Alexander had committed three attempted murders and one murder;
used a firearm multiple times in public settings;
killed an innocent woman in her own home; and
was already on bail for a previous attempted murder;

the Court held that the minimum term could not be said to be manifestly excessive, even for a 16‑year‑old with the mitigating features present.

This firmly indicates that:

In the most extreme cases of gang‑related gun violence by children, minimum terms approaching those for adults, and well above the basic youth starting points, may be upheld on appeal where required to reflect the seriousness and totality of the offending.

3.6 Procedural fairness and legal aid

A noteworthy, if secondary, aspect of the judgment is the Court’s decision to extend legal aid funding for Alexander’s solicitor:

to attend the appeal hearing; and
to communicate with him afterwards.

The Court explicitly linked this to:

his documented comprehension and developmental difficulties; and
the need for him to properly understand the outcome and reasons for the appeal decision.

This reflects a broader trend in appellate practice: recognition that where a young or vulnerable defendant has cognitive limitations, effective participation in proceedings may require enhanced legal support, even at appeal stage.

4. Complex Concepts Simplified

This section explains several legal concepts that feature prominently in the judgment.

4.1 Expert evidence

What is it? Evidence from someone with special knowledge, skill or experience on a topic beyond the ordinary understanding of jurors (for example, gang structures in a specific borough).
Why is it allowed? To assist the jury by providing context or technical explanations.
Key requirements (post‑Myers):
- The witness’s expertise must be real and demonstrable (through experience or study).
- They must clearly explain:
  - what material they rely on; and
  - the limits of their knowledge.
- The judge acts as a gatekeeper, deciding what the jury can hear.

4.2 Bad character, s.98 and s.101 CJA 2003

Bad character normally covers evidence of misconduct other than the offence being tried (e.g. previous convictions, gang incidents).
s.98 CJA 2003 excludes from “bad character” anything “to do with the facts of the offence”. For example, evidence of gang rivalry or association that explains why a particular assault occurred.
s.101(1)(d) CJA 2003 allows bad character to be admitted if it is relevant to an important issue – such as whether a defendant’s contact with co‑defendants was innocent or criminal.
s.101(3) CJA 2003 / s.78 PACE 1984 give the court a discretion to exclude evidence that would make the trial unfair, even if technically admissible.

4.3 Unsafe conviction

The Court of Appeal can overturn a conviction if it considers it unsafe (Criminal Appeal Act 1968).
“Unsafe” does not mean simply that another jury might have acquitted. It requires a real concern that something went seriously wrong:
- admission of highly prejudicial and irrelevant evidence;
- a serious misdirection of law;
- unfairness in the conduct of the trial.
Minor or neutral errors in summing‑up rarely meet this threshold.

4.4 Manifestly excessive sentence and disparity

The Court of Appeal will interfere with a sentence if:
- it is wrong in principle (e.g. misapplication of a guideline); or
- it is manifestly excessive, i.e. so high that it falls outside the reasonable range a judge could impose for the offence and offender.
Disparity occurs when co‑defendants receive sentences that appear inconsistent, raising potential unfairness.
However, co‑defendants’ sentences will only justify intervention if the difference is so great and so unjustified as to show one sentence is wrong in principle or manifestly excessive. The bar is high.

4.5 Detention during His Majesty’s Pleasure (DHMP)

A form of indeterminate sentence for murder committed by those under 18.
The court:
- must impose DHMP; and
- then sets a minimum term before which the offender cannot be considered for release by the Parole Board.
After the minimum term, release is not automatic; it depends on risk assessment.

4.6 Youth sentencing and developmental age

The Overarching Youth Guideline stresses that:
- children and young people have reduced culpability compared with adults;
- their developmental age may differ from chronological age;
- custodial sentences should be a last resort and as short as is commensurate with the seriousness of the offence.
Nevertheless, for very serious offences like murder and attempted murder, substantial sentences – including very long minimum terms – may be imposed, especially where:
- the offending is persistent and escalates;
- there is planning and weapon use; and
- public protection is a central concern.

5. Likely Impact and Broader Significance

5.1 Gang expert evidence

This judgment will likely be cited in future as authority for:

the proposition that police gang officers with focused local experience can be accepted as expert witnesses, even with modest years of service and no formal “expert” title;
the admissibility of their opinions on:
- gang rivalries;
- the significance of social media communications; and
- the association of particular individuals with specified gangs;
provided they are transparent about the basis and limits of their knowledge.

For defence practitioners, this underscores the importance of:

rigorous challenge at admissibility hearings to ensure proper scrutiny of gang “expert” credentials and methodology;
effective cross‑examination at trial to expose any over‑statement or speculation.

5.2 Bad character, gang association and risk of prejudice

The Court’s approach signals:

a continued willingness to admit limited prior incidents as evidence of gang association and motive;
a reluctance to treat such evidence as unfairly prejudicial where:
- it is only one component in a broader evidential mosaic; and
- there is no indication the jury relied on it disproportionately.

In practical terms:

Prosecutors will be encouraged to continue to use admissions and concise gang histories to contextualise serious youth violence.
Defence teams will need to focus on:
- limiting the breadth of such evidence;
- securing clear judicial directions on its restricted use (e.g. motive, association); and
- distinguishing mere association from proof of participation in joint enterprise.

5.3 Youth sentencing in gang‑related homicide

On sentencing, the case underlines several points:

Extreme sentences for child gang members are sustainable: Where a 16‑year‑old commits a murder and multiple attempted murders with a firearm, in a gang context and while on bail, minimum terms approaching three decades can be upheld, even in the face of evidence of trafficking and cognitive impairments.
Trafficking and exploitation are mitigation, not immunity: The Court explicitly accepts that Alexander was a victim of trafficking and modern slavery, and that his developmental age was lower than his chronological age. Yet, due to the extreme seriousness and persistence of the offending, such mitigation did not reduce the sentence below a 28‑year minimum term.
Organisers and co‑ordinators may receive higher sentences than on‑scene attackers: In joint enterprise cases, a youth who co‑ordinates and enables a gang shooting can receive a higher sentence than younger, weapon‑wielding co‑defendants.

These themes suggest a strong judicial emphasis on:

public protection and deterrence in serious gang‑related firearm offending by youths;
holding young offenders fully accountable where they have made repeated and conscious choices to escalate their violence, despite previous interventions.

5.4 Appellate restraint in sentence review

The judgment reaffirms the Court of Appeal’s traditional restraint:

on disparity arguments in joint enterprise sentencing; and
on re‑weighing complex mitigation where the trial judge has heard detailed evidence over many days.

It reinforces that:

The appellate court’s role is not to fine‑tune sentences, but to correct errors of principle or sentences so far outside the range as to be manifestly excessive.

6. Conclusion

R v Edokpolo & Alexander [2025] EWCA Crim 1534 is a significant modern authority in the law of serious youth violence. It clarifies that:

Police gang officers with focused local experience can be treated as expert witnesses, provided their evidence is properly scrutinised and confined to defined issues such as motive and association.
Evidence of prior gang‑related incidents, even of limited scale, may legitimately be admitted to demonstrate association and motive, so long as its probative value outweighs the risk of unfair prejudice and it is not allowed to dominate the case.
Summing‑up complaints will only undermine the safety of a conviction where comments seriously misrepresent or dilute the defence case; minor neutralising remarks about technical matters will not suffice.
In sentencing:
- youth and vulnerability, including trafficking and low IQ, attract real mitigation, but
- do not preclude very long minimum terms where the offending involves multiple murders and attempted murders with firearms, especially in a gang context and while on bail.
Organisers and co‑ordinators in joint enterprise may be treated as at least as culpable – and sometimes more so – than those physically present, justifying higher sentences even among youths.

The case thus stands as a reference point for:

the continued judicial acceptance of police‑led gang expertise; and
the willingness of the appellate courts to uphold exceptionally stern sentences for child offenders involved in the most serious forms of gang‑related gun violence, notwithstanding substantial mitigation.

In the broader legal landscape, Edokpolo & Alexander confirms that the criminal courts will simultaneously:
- recognise the complex vulnerabilities of young gang‑involved defendants; yet
- impose sentences that strongly reflect the gravity, persistence and public danger of their offending when they engage in orchestrated lethal violence.