R v Singh [2025] EWCA Crim 1520: Murder “Done for Gain” in a Domestic, Delusional Context – Mixed Motives, Mental Disorder and Minimum Terms under Schedule 21

1. Introduction

This commentary analyses the judgment of the Court of Appeal (Criminal Division) in R v Singh [2025] EWCA Crim 1520, a life sentence appeal arising from the murder of an elderly mother by her son. The case is important for three overlapping reasons:

It clarifies when a domestic killing, motivated by a long-running dispute about property and money and coloured by delusional beliefs, can properly be categorised as a “murder done for gain” under paragraph 3(2)(c) of Schedule 21 to the Sentencing Act 2020.
It re‑emphasises, by applying R v Tailor and R v Hoadley, that in domestic murders for gain with mixed motives the 30‑year starting point may require downward adjustment before aggravating and mitigating factors are applied.
It explains the proper treatment of mental disorder falling short of diminished responsibility in such cases, and corrects a tendency to treat an intention to kill as aggravating in itself.

The appeal did not disturb the finding of murder, but successfully challenged the minimum term. The Court reduced the minimum term from 31 years (less remand) to 25 years (less remand), with a calculated minimum term of 24 years and 148 days, and also addressed an unlawful administrative imposition of the statutory surcharge.

2. Factual and Procedural Background

2.1 The homicide

On 13 May 2024, the appellant, Mr Singh, went to the Leicester home of his 76‑year‑old mother, Bhajan Kaur. She was alone. He entered the house and subjected her to what the prosecution described as a “savage beating”:

31 sites of blunt force trauma were found on external examination, with a further 3 internal sites;
the injuries covered her head, face, arms and body.

He then placed a plastic bag over her head, held it against her nose and mouth and smothered her. Afterwards he cleaned blood from the floor, changed his clothing, and went out to buy a spade and sack trolley. He returned, loaded his mother’s body onto the trolley and began digging a grave in the back garden.

He was interrupted when his sister, Kalbinder Cheema, arrived to visit their mother. She discovered the body and called 999. The appellant was seen at the property and denied involvement, even suggesting that his sister was responsible. He left and was arrested nearby, carrying:

over £500 in cash; and
his mother’s bank card.

In interview he denied killing his mother. At trial he advanced a defence of complete denial and, in the alternative, diminished responsibility. Both were rejected by the jury, which convicted him of murder.

2.2 The pre‑offence background: delusions, control and threats

Bhajan Kaur lived at the family home with her husband until his death in 2020. The couple had three children: the appellant, a sister and a brother. After the breakdown of his marriage the appellant stayed regularly at the property.

After his father’s death his behaviour changed markedly:

He formed a delusional belief that his father had intended to leave him the house and that it was his property.
He became increasingly aggressive towards his mother and siblings.
He repeatedly tried to force his mother out of the house, arguing that she should live with her eldest son.
She described him as controlling and coercive; he demanded money and made her feel bad if she refused.

Mrs Kaur made two police statements, on 11 September 2023 and 2 May 2024, describing:

threats to kill her, including telling her to take all her tablets at once or hang herself;
taking her cash, bank cards and mobile phone so she could not call for help;
physically expelling her from the house and barricading the door against her re‑entry;
missing gold jewellery worth £4,000–£5,000;
threats to stab carers and his sister, and to kill his brother and nieces/nephews.

The appellant was twice arrested and bailed with conditions not to contact his mother or attend the Bolsover Street property. He ignored those conditions, sleeping in his car on the driveway. He maintained that the house was his, and claimed his mother was “mental” and ought to be moved to a care home.

He also told his nephew there was a will relating to the property which was not being honoured, reinforcing the theme of a perceived entitlement to the house and its value.

2.3 The trial and original sentence

At trial, the Crown relied on:

evidence from the appellant’s siblings and sister‑in‑law;
the deceased’s two statements, read as hearsay;
expert psychiatric evidence from three psychiatrists (Drs Thirumalai, Davies and Rogers) on diminished responsibility.

The appellant did not give evidence. The jury rejected both the denial and the partial defence of diminished responsibility.

On 16 December 2024, the Crown Court at Leicester sentenced him to life imprisonment. Her Honour Judge Tayton KC:

categorised the case under paragraph 3 of Schedule 21 (30‑year starting point) as a “murder done for gain” within paragraph 3(2)(c);
treated various aggravating features as justifying an upward move to 36 years;
then applied mitigating factors, principally the appellant’s mental illness, to reach a minimum term of 31 years.

Time on remand (217 days) was not announced in court but yielded a term of 30 years and 148 days.

2.4 The appeal

The appellant appealed the minimum term with leave of the single judge. His principal arguments (advanced by leading counsel, Mr Lloyd‑Jones KC) were that:

this was not a “murder done for gain”, so paragraph 3 of Schedule 21 was wrongly applied;
even if it was, the judge:
- did not properly account for Tailor and Hoadley regarding mixed motives in domestic killings for gain; and
- failed to give sufficient weight to the lack of premeditation and the appellant’s serious mental disorder.
the judge appeared to treat the intention to kill as an aggravating factor;
in accordance with R v King [2017] EWCA Crim 128, any uncertainty about motive should have been resolved in the appellant’s favour.

For the Crown, Mr Vout KC contended that:

the history of threats, coercive behaviour and property‑focused delusion fully justified categorising the murder as “for gain”, whether in respect of cash or the house;
the examples in the brackets in paragraph 3(2)(c) are not exhaustive;
the sentencing judge’s overall analysis was sound, save for minor clarifications.

3. Summary of the Judgment

The Court of Appeal (Her Honour Judge Tayton KC giving the judgment) held that:

The sentencing judge was entitled to conclude, on the evidence, that this was a murder done for gain, properly falling within paragraph 3(2)(c) of Schedule 21. The case was centred on the appellant’s desire to obtain or secure control of the family home and money, even if motivated by delusion.
However, in light of R v Tailor and R v Hoadley, this case belonged to the category of domestic murders for gain with mixed motives, so an initial reduction from the 30‑year starting point should have been made before applying aggravating and mitigating factors.
The intention to kill should not be treated as an aggravating factor; rather, it prevents the offender from relying on the mitigating factor in paragraph 10(a) (lack of intention to kill).
The appellant’s serious mental illness, although insufficient for diminished responsibility, significantly reduced his culpability and warranted a substantial reduction of the minimum term under paragraph 10(c).
Taking those points together, the Court reduced the minimum term from 31 years (less remand) to 25 years (less remand). Following Sesay [2024] EWCA Crim 483, it calculated the precise term as 24 years and 148 days.
Finally, the Court held that an administratively added statutory surcharge of £228 was unlawful, following R v Jones [2018] EWCA Crim 2994, and ordered the Crown Court record to be corrected to remove it.

The appeal against sentence was therefore allowed in part—the life sentence remained, but the minimum term was substantially reduced.

4. Detailed Analysis

4.1 The statutory framework: Schedule 21 Sentencing Act 2020

Schedule 21 (now part of the Sentencing Act 2020) governs the determination of minimum terms for mandatory life sentences for murder. The process is broadly:

Identify the appropriate starting point (e.g. 15, 25, 30 years, or whole life) based on the seriousness of the case and specified categories.
Adjust up or down to reflect aggravating and mitigating factors (paras 9 and 10) to arrive at a just minimum term.

In this case:

Paragraph 3(1) provides a 30‑year starting point where the seriousness is “particularly high”.
Paragraph 3(2) lists illustrations of such cases, including:
(c) a murder done for gain (such as a murder done in the course or furtherance of robbery or burglary, done for payment or done in the expectation of gain as a result of the death).

The main disputes were:

whether this killing fell within “murder done for gain”; and
how far mental disorder and other features should move the case away from or within that 30‑year bracket.

4.2 Was this a “murder done for gain”?

4.2.1 The evidential basis

The Court relied on an evidential tapestry rather than a single incident:

Repeated threats to kill his mother and force her out of the house;
Coercive and controlling behaviour, especially around money and property;
The appellant’s persistent insistence that the house was his, notwithstanding Land Registry evidence to the contrary;
The deceased’s fear of him, evidenced by multiple police complaints;
Statements that she would “take all the money with her when she died”;
The appellant’s efforts over four years to displace her from the house, including barricading the doors;
His post‑offence conduct: cleaning up, attempting to bury the body, false accusations against his sister, leaving the house with his mother’s bank card and significant cash; and
His interviews, where he repeatedly linked the killing to a four‑year history starting with his father’s death and his perceived dispossession of the house.

The Court noted that in R v Healey [2008] EWCA Crim 2583 the sentencing judge was “entitled to form his own view, having heard the evidence, on whether the murder was or was not done for gain.” Here, having heard the trial, the judge was similarly entitled, and the appellate court agreed.

4.2.2 Delusional belief and the concept of “gain”

An important defence argument was that the appellant was deluded into believing he already owned the house. If he thought it was his, could he be said to have killed “in the expectation of gain” as a result of the death?

The Court effectively answered “yes”, for two reasons:

Objective assessment of motive: Even if the appellant believed he already owned the house, his behaviour demonstrated that he saw his mother as an impediment to his effective enjoyment or control of it. Her death would remove that impediment and thus provide a clear practical gain.
Bracketed examples not exhaustive: The defence sought to limit paragraph 3(2)(c) by reference to its examples (“such as” robbery, burglary, payment, expectation of gain). The Court endorsed the Crown’s submission that these are illustrative, not exhaustive. A killing driven by a desire to secure or consolidate an asset can still be “for gain” even if the defendant is labouring under a delusion about title.

The Court concluded (para 27) that:

Taking an objective view of the evidence, we are satisfied that this murder is correctly categorised as a murder done in the expectation of gain.

The decision thus clarifies that mental disorder does not negate the categorisation of a killing as “for gain”, even where the gain is filtered through a delusional lens. Instead, it is addressed separately as a mitigating factor (para 10(c)).

4.2.3 The role of R v King and the “most favourable” basis

The defence invoked R v King [2017] EWCA Crim 128, arguing that where more than one inference about motive is reasonably open and cannot be resolved, the court must sentence on the basis most favourable to the defendant.

The Court of Appeal implicitly held that this principle did not assist the appellant:

The evidential picture did permit a finding, to the criminal standard, that the killing was part of a sustained effort to achieve gain in relation to the house.
While the precise proximate trigger (e.g. a refusal of cash that day) could not be known, the broader gain‑focused motivation was sufficiently established.

Thus, King applies only where the evidence leaves genuinely irreconcilable possibilities about key factual bases. Here, the Court held that the trial judge could be sure the murder was done for gain, and the Court endorsed that conclusion.

4.3 Mixed motives and the Tailor / Hoadley line

The more significant legal development lies in the Court’s handling of mixed motives, building on R v Tailor [2007] EWCA Crim 1564 and R v Hoadley [2009] EWCA Crim 1885.

In Tailor, Mitting J observed (para 20) that paragraph 3(2)(c):

… is apt to include those cases where the husband murders his wife in the knowledge, and so in the expectation, that he will thereby not only achieve other ends (e.g. to satisfy lust and selfishness) but also, if not discovered, that he will make a significant financial gain. Such cases are, in our view, ordinarily to be distinguished from those where professional criminals kill for gain, or where they kill in the course of executing a serious offence of violence and dishonesty such as robbery. Cases of mixed motives will not ordinarily require a minimum term as long or that appropriate in such cases.

The appellant relied on this passage to argue that:

This was a domestic killing with mixed motives (anger, control, delusion, resentment), not a pure professional “for gain” killing;
The judge should therefore have started below 30 years even within the paragraph 3 framework, before layering on aggravation or mitigation.

The Court accepted this argument in principle:

It endorsed the Tailor/Hoadley distinction between professional for‑gain murders (e.g. contract killings, robberies) and domestic murders in which financial gain is only one—often not the primary—motivation.
It described this case as one in which the appellant’s gain‑related motive co‑existed with other motivations (rage, domination, resentment).
It concluded that the judge should have made an initial reduction from the 30‑year starting point to reflect that this was not a prototypical “professional” gain killing.

Although the Court did not publish a precise mathematical sequence, its reasoning implies a structure such as:

Start at 30 years under paragraph 3(2)(c) (murder for gain);
Reduce somewhat (implicit) to reflect Tailor‑type mixed motives in a domestic setting;
Increase for aggravating factors (vulnerability, previous coercive behaviour, concealment, location);
Reduce significantly for mental disorder under paragraph 10(c);
Arrive at 25 years as the appropriate minimum term before remand.

The key doctrinal message is that falling within paragraph 3 does not automatically fix the minimum term at or above 30 years. In domestic “for gain” cases with mixed motives, the court must still exercise judgment within that band and can move below 30 years before applying the usual aggravating and mitigating factors.

4.4 Mental disorder short of diminished responsibility (paragraph 10(c))

The jury’s rejection of diminished responsibility did not mean that mental illness was irrelevant to sentencing. Paragraph 10(c) of Schedule 21 identifies as mitigating:

the fact that the offender suffered from any mental disorder or mental disability which (although not falling within section 2(1) of the Homicide Act 1957) lowered the offender’s degree of culpability.

The Court emphasised:

The appellant’s delusional thinking was chronic and persistent (Dr Thirumalai);
He had serious mental health issues and had been detained twice under the Mental Health Act 1983 with treatment by antipsychotics;
Dr Davies’ report also evidenced longstanding serious mental health problems from at least 2021, even though he was less certain as to diagnosis.

Although the threshold for diminished responsibility (substantial impairment of responsibility) was not crossed in the jury’s view, the Court accepted the sentencing judge’s conclusion that the appellant’s delusional disorder significantly reduced his culpability.

This case therefore reinforces three important propositions:

A failed diminished responsibility defence does not preclude a substantial discount under paragraph 10(c).
Mental disorder can be a major mitigating factor even where the offence falls within the most serious starting‑point categories, such as paragraph 3.
The fact that a gain‑oriented motive is rooted in delusion does not negate the “for gain” categorisation, but does strongly support mitigation as to culpability.

4.5 Intent to kill: neutral factor, not aggravation

The Court scrutinised the sentencing remarks which stated:

Further aggravation is provided by the fact that this was a killing within her own home, and I am satisfied that there was an intent to kill here.

The Court observed that this could be read as treating intent to kill as an aggravating factor. It noted that the transcript was ambiguous—perhaps the judge meant only that the location was aggravating, with the intention to kill mentioned as a separate factual finding.

However, the Court took the opportunity to state the correct approach:

Under paragraph 10(a) of Schedule 21, a mitigating factor is that:
the offender intended to cause serious bodily harm rather than to kill.
Thus, an absence of intent to kill is mitigating. Conversely, a presence of intent to kill is ordinarily the baseline for murder, not an aggravating factor.
It would have been better for the judge to say that the presence of an intention to kill meant that paragraph 10(a) did not apply, rather than suggesting that intention to kill itself aggravated the offence.

The judgment therefore reinforces the orthodox principle: intent to kill is not, without more, an aggravating factor; what is mitigating is an intent limited to really serious harm.

4.6 Calculating and adjusting the minimum term

Putting the strands together, the Court’s reasoning on the final figure can be unpacked conceptually as follows (even though no precise arithmetic is set out):

Category and starting point:
- The case does fall within paragraph 3(2)(c) as a murder “done for gain”.
- Therefore, a 30‑year starting point applies in principle.
Within‑category adjustment for mixed motives:
- Applying Tailor and Hoadley, a domestic killing for gain with mixed motives does not necessarily justify holding to the full 30‑year baseline.
- The Court held that the sentence should have started somewhat below 30 years before aggravation/mitigation were applied.
Aggravating features (para 9 and common law):
- Victim’s particular vulnerability by virtue of her age (76) and frailty;
- A prolonged pattern of controlling and coercive behaviour directed at the victim;
- The appellant’s attempt to conceal the body (cleaning, buying a spade and trolley, starting to dig a grave);
- The killing in the victim’s own home, a place where she should have been safe;
- A clear intention to kill (which, as explained, is neutral in itself but removed a possible mitigating factor).
Mitigating factors (para 10):
- Lack of evidence of , though the attack itself was determined and sustained;
- Rapid loss of consciousness after suffocation, indicating no prolonged conscious suffering (limited mitigation);
- Most significantly, the appellant’s chronic delusional disorder, plainly lowering his culpability within paragraph 10(c).
Outcome:
- Balancing all these, the appropriate minimum term before remand is 25 years.
- After deducting 217 days of remand, and following Sesay [2024] EWCA Crim 483 guidance, the Court specified the minimum term precisely as 24 years and 148 days.

This careful structuring shows the Court’s commitment to a two‑stage approach: first categorisation and within‑bracket assessment (including Tailor‑type adjustments), then aggravation/mitigation.

4.7 The statutory surcharge and R v Jones

The final point concerns the statutory surcharge under s.42 Sentencing Act 2020. The Crown Court record sheet showed that a £228 surcharge had been imposed. However:

The sentencing remarks suggested that the judge had not actually imposed the surcharge.
The surcharge appeared to have been added administratively.

In R v Jones [2018] EWCA Crim 2994; [2019] 1 Cr App R (S) 50 at [15], the Court held that:

If a surcharge is not ordered in open court, but added later administratively, the order is not lawful.
Although the surcharge is mandatory, the Court of Appeal is precluded by s.11(3) Criminal Appeal Act 1968 from imposing it itself where it was not imposed at first instance.

Following that approach, the Court in Singh ordered the Crown Court record to be corrected to remove the surcharge. This preserves both:

the principle that sentencing must occur in open court; and
the statutory limitation on appellate powers where the effect would be to impose a more severe sentence.

5. Precedents Cited and Their Use

5.1 R v Healey [2008] EWCA Crim 2583

Cited for the proposition that a sentencing judge, having heard the evidence, is entitled to form his or her own view on whether a murder was done for gain. The Court used this to emphasise its deference to the trial judge’s assessment of motive, provided there is evidential support.

5.2 R v King [2017] EWCA Crim 128

Invoked by the defence as authority for sentencing on the basis most favourable to the offender where key facts are uncertain. Although not expressly distinguished, King was effectively limited to genuinely equivocal cases. Here, the Court held that the evidence did allow a sure finding that the murder was done for gain.

5.3 R v Tailor [2007] EWCA Crim 1564 and R v Hoadley [2009] EWCA Crim 1885

These authorities were pivotal. Tailor framed the distinction between:

professional or robbery‑related murders for gain; and
domestic murders where gain is one element among mixed motives.

Hoadley followed and reinforced that analysis. In Singh, the Court accepted that this case fell into the latter category and therefore warranted a downward movement from 30 years at the outset, before further adjustments.

5.4 Sesay [2024] EWCA Crim 483

Relied on for guidance on how the Court of Appeal should express minimum terms after deducting time spent on remand. The Court explicitly followed Sesay in calculating and stating the net minimum term of 24 years and 148 days.

5.5 R v Jones [2018] EWCA Crim 2994

Applied in relation to the statutory surcharge. The Court reaffirmed that an administratively added surcharge is unlawful and cannot be retrospectively validated by the Court of Appeal; instead, the record must be corrected to remove it.

6. Explanation of Key Legal Concepts

6.1 Minimum term for a mandatory life sentence

For murder, the court must impose a life sentence, but it also sets a minimum term. This is the minimum period the offender must serve in custody before being eligible to have the Parole Board consider release. It is not a guarantee of release at that point.

6.2 “Murder done for gain” – paragraph 3(2)(c)

A murder “done for gain” includes situations where the offender:

kills during robbery or burglary;
kills for payment (e.g. a contract killing); or
kills “in the expectation of gain as a result of the death” (for example, to benefit from inheritance or insurance).

Singh confirms that:

The list is illustrative, not exhaustive;
Gain may be indirect or long‑term (such as securing a home after a campaign of dispossession), not only immediate theft;
Even if the offender’s belief about entitlement is delusional, the killing can still be categorised as “for gain” on an objective assessment.

6.3 Mixed motives

Many domestic murders involve intertwined motives—anger, jealousy, control, revenge, and sometimes financial gain. Tailor and now Singh recognise that where gain is only one component of a broader emotional or domestic context:

The case may still fall within paragraph 3(2)(c); but
The court should be cautious about using the full 30‑year baseline, and may appropriately start lower within that serious category.

6.4 Diminished responsibility vs mental disorder as mitigation

Diminished responsibility (s.2 Homicide Act 1957, as amended) is a partial defence which, if proved, reduces murder to manslaughter. It requires that:

The defendant suffers from an abnormality of mental functioning from a recognised medical condition;
Which substantially impairs his ability to understand the nature of his conduct, form a rational judgment, or exercise self‑control;
And provides an explanation for the killing.

If a jury rejects diminished responsibility, mental disorder has not been proved to that extent. However, under paragraph 10(c) of Schedule 21, mental disorder which does not meet that threshold can still be considered as mitigating if it lowers culpability.

In Singh, the jury’s rejection of diminished responsibility did not stop the Court from treating the appellant’s chronic delusional disorder as a major mitigating factor.

6.5 Hearsay evidence of the deceased’s statements

The deceased’s two statements to the police were read at trial as hearsay—evidence from a person not giving live testimony. Under the Criminal Justice Act 2003, such statements may be admitted in specified circumstances (for example, where the witness is dead), subject to fairness considerations.

In this case those statements were crucial in:

establishing the appellant’s controlling and coercive behaviour;
demonstrating his threats and financial demands;
showing the long‑running dispute about the house and money.

They formed an important part of the evidential basis for classifying the murder as “done for gain”.

6.6 Statutory surcharge

The statutory surcharge is a financial penalty imposed in addition to other sentences to help fund victim services. It is mandatory in most cases, but:

It must be announced and imposed in open court by the sentencing judge;
It cannot lawfully be added administratively later;
The Court of Appeal cannot use its powers to correct the omission by imposing it for the first time, where that would make the sentence more severe (s.11(3) Criminal Appeal Act 1968).

Singh applies this principle to remove an administratively added surcharge.

7. Likely Impact and Future Application

The judgment has several practical and doctrinal implications for future cases.

7.1 Broadening and clarifying “murder for gain” in domestic contexts

Courts can be more confident in classifying domestic killings as “done for gain” where:

There is a pattern of behaviour involving threats, coercion and attempts to secure control of a house or assets;
The victim is an impediment to the offender’s enjoyment or control of the asset;
The killing brings about, or is intended to bring about, the removal of that impediment, even if the immediate trigger is an argument or emotional outburst.

Motive rooted in delusional beliefs about entitlement does not prevent a finding of “for gain”; instead it moves the focus onto mitigation under paragraph 10(c).

7.2 Reinforcing the Tailor/Hoadley distinction

For sentencing judges, Singh is a reminder that:

Not all murders falling within paragraph 3(2)(c) demand a full 30‑year starting point;
In domestic, mixed‑motive cases, it may be necessary to come down from 30 years before applying aggravating and mitigating factors;
Nevertheless, very serious aggravating features—vulnerability, cruelty, concealment—may still drive the term back up.

Sentencers must therefore engage in a nuanced assessment, not a mechanistic application of the Schedule 21 table.

7.3 Mental disorder as a substantial mitigating factor even in high‑seriousness categories

The decision confirms that:

Serious mental illness can and should substantially reduce the minimum term, even where the offence sits within the highest non‑whole‑life category under Schedule 21;
Courts must distinguish between:
- the role of mental disorder in establishing a partial defence; and
- its role in sentencing mitigation despite the failure of that defence.

For practitioners, this underscores the importance of robust psychiatric evidence not only at trial but also at sentence and on appeal.

7.4 Sentencing methodology: clarity about intent and structure

The Court’s comments on the treatment of intention to kill will help avoid recurring errors where judges:

mistakenly list “intent to kill” as an aggravating factor; or
fail to frame it correctly as the absence of a potential mitigating factor under paragraph 10(a).

It also illustrates the desirability of sentencing remarks that clearly separate:

identification of the starting point under Schedule 21;
any within‑category adjustments (e.g. for mixed motives);
the step‑by‑step application of aggravating and mitigating factors.

7.5 Administrative surcharges and appellate limits

Finally, the surcharge point has practical implications:

Crown Court staff must not assume they can “correct” perceived judicial omissions by adding surcharges administratively;
Where such an addition has occurred, the remedy is for the record to be corrected, not for the Court of Appeal to impose the surcharge afresh.

8. Conclusion

R v Singh [2025] EWCA Crim 1520 is a significant sentencing decision in the law of murder. It affirms that:

A domestic killing can be a “murder done for gain” where the offender kills a relative seen as an impediment to securing control of property or money, even if that perception is delusional.
The bracketed illustrations in paragraph 3(2)(c) of Schedule 21 are non‑exhaustive. Gain may be long‑term, indirect and embedded within a domestic power struggle.
Nonetheless, in such domestic, mixed‑motive cases, the full 30‑year starting point is not inevitable. Following Tailor and Hoadley, an initial downward adjustment within the category can be appropriate.
Mental disorder that falls short of diminished responsibility can substantially lower culpability and justify a meaningful reduction in the minimum term, even for very serious murders.
Intention to kill is a neutral feature of murder; it cancels a potential mitigating factor, but does not aggravate the offence in itself.
Administrative imposition of the statutory surcharge is unlawful; it must be imposed by the court in open session, and the appellate court’s power to correct omissions is constrained.

By reducing the minimum term from 31 years to 25 years (pre‑remand), the Court of Appeal recognises both the gravity of a brutal matricide committed in the victim’s own home and the substantial mitigating weight of serious mental disorder and the domestic, mixed‑motive context. Singh will stand as a key authority on the interaction between “murder for gain”, mental illness, and the calibrated use of the Schedule 21 framework.