Latham, R. v

Factual and Procedural Background

The Appellant applied for leave to refer the Defendant's sentence as unduly lenient. The Defendant pleaded guilty on various occasions to a large number of sexual offences against multiple young female victims occurring between April 2023 and April 2024, with concentrated online offending in March–April 2024. Sentencing took place on 19 September 2025 before Judge Parry in the Crown Court at The City. The aggregate disposal was an extended sentence under section 279 of the Sentencing Act 2020 of 22 years (14 years custody plus 8 years extended licence), imposed after the judge aggregated offences under three indictments referred to in the opinion as case 4124, case 8324 and case 6624. The offences included rape of a child under 13, multiple counts of making and distributing indecent photographs, sexual activity with children, causing or inciting children under 13 to engage in sexual activity, sexual communications with children, blackmail and possession of an extreme pornographic image. Victim reporting originated from The Agency and school and medical disclosures; digital forensic analysis of devices revealed extensive child sexual abuse material and recorded interactions with numerous children.

Legal Issues Presented

1. Whether the sentence imposed by the Crown Court was unduly lenient.
2. Whether the judge's categorisation of the principal offences and individual starting points and ranges were within the range properly open to him.
3. Whether the reductions applied by the judge for plea and for the Defendant's personal mitigation (age and personal circumstances) were appropriate.
4. Whether the principle of totality was properly applied in aggregating the offences and fixing the custodial term and extension period.
5. Whether the extension period of 8 years was justified and proportionate in the circumstances.

Arguments of the Parties

Appellant's Arguments

• The overall sentence was too low given the scale, variety and persistence of offending, including blackmail, repeated offending while on bail, and extensive online targeting of dozens of children.
• Count 1 (the rape of Victim 1) being placed in harm category 3 was contestable and the reduction to a notional 7 years before plea discount was open to question; even accepting that notional figure, the aggregate notional sentence before mitigation and plea was submitted to be materially higher than that adopted by the judge.
• The judge should have imposed a significantly longer aggregate sentence when addressing totality, because the offences fall into multiple distinct types and the cumulative harm required a heavier overall sentence.
• Blackmail offences and the preponderance of offending while on bail were particularly aggravating features warranting a higher sentence.

Defendant's Mitigation and Positions Identified in the Record

• The Defendant advanced limited responsibility and disputed aspects of factual characterisation: he accepted some deception about age but denied grooming and, at times, denied offending; later he pleaded guilty on various counts.
• Mitigation relied upon the Defendant's relative youth and personal circumstances, including material in pre-sentence reports and an addendum disclosing prior victimisation of the Defendant.
• Defence submissions included an argument (rejected by the judge) that the rape count should be categorised differently on account of an absence of grooming.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The court reviewed the sentencing exercise and the Appellant's challenge. It found that:

• The judge's categorisations of offences and the chosen starting points and ranges were within the range reasonably open to him; each categorisation was supported by concise explanations in the sentencing remarks.
• The plea discounts applied (20–25% depending on the count) were not challenged successfully and fell within permissible bounds given the chronology and nature of the pleas.
• There was more room to question the scale of reductions made for the Defendant's personal mitigation. The judge applied substantial reductions for personal mitigation (in some instances around 37%), relying on the Defendant's age and "all his personal circumstances." The appellate court accepted that reductions for relative youth and circumstances were justifiable, including reference to the addendum disclosing the Defendant's prior victimisation, but considered some individual reductions to be at or beyond the outer limit of reasonableness.
• Overall, a global reduction of about 25–30% for personal mitigation was judged justifiable. Arithmetic showed the imposed custodial term of 14 years (after plea discount) was comparable to a notional pre-mitigation sentence in the mid-20s years for a fully mature adult; the court regarded that equivalent as reflecting a very heavy sentence appropriate to the conduct complained of.
• Having considered the principle of totality, the aggregate approach taken by the judge (aggregating on Count 1 and applying totality to fix the custodial term and the maximum 8-year extension) was carefully explained and correctly applied in context.
• Accordingly, although some reductions for personal mitigation were viewed as generous, the court concluded that the judge's overall exercise of sentencing discretion was within the appropriate range and not unduly lenient.

Holding and Implications

The court granted leave to refer but refused to increase the sentence.

Direct effect: The extended sentence of 22 years (14 years' custody plus an 8-year extended licence) as imposed by Judge Parry remains undisturbed. The court declined to intervene to increase the sentence. The opinion records that no new legal precedent was established; the decision affirms that the sentencing judge's exercise of discretion, including categorisation, plea discounts and the application of totality with a substantive mitigation allowance for youth and personal circumstances, was within reasonable bounds in this case.