Armani, R. v

Factual and Procedural Background

Judge Holgate delivered this opinion concerning a renewed application for leave to appeal against sentence by the Appellant. The Appellant pleaded guilty in a Magistrates' Court on 14 October 2023 to one offence under section 329 of the Proceeds of Crime Act 2002 (case 62CL0807123). The Appellant also pleaded guilty on 14 December 2023 in the same court to offences under section 327 and section 329 of the 2002 Act and to two offences of being concerned in the supply of controlled drugs (case 62CL0936323). On 2 May 2025 Judge Jenkins in the Crown Court sentenced the Appellant to a total of 15 years' imprisonment composed of 13 years 6 months for being concerned in the supply of cocaine, concurrent terms for the other drug and money laundering offences, and a consecutive term of 18 months for the s.329 offence under case 62CL0807123. The Appellant renewed an application for leave to appeal against that sentence following refusal by a single judge.

Legal Issues Presented

1. Whether the overall sentence of 15 years was manifestly excessive.
2. Whether the sentencing Judge erred in the starting point applied to the cocaine offence (including whether an 18-year starting point was appropriate).
3. Whether the Appellant was entitled to a greater credit for earlier guilty pleas (including credit for pleas entered in the Magistrates' Court).
4. Whether the sentences for the various offences should have been ordered to run concurrently rather than, in part, consecutively.

Arguments of the Parties

Appellant's Arguments

• The starting point of 18 years for the cocaine offending was too high and should have been closer to 12–13 years.
• The Appellant was entitled to a 33% discount for pleas entered in the Magistrates' Court.
• Greater weight should have been given to mitigating factors, including the Appellant's lack of relevant previous convictions and a diagnosed gambling disorder.
• All sentences should have been ordered to run concurrently.

Respondent's / Crown's Position (as reflected in the single judge and Crown Court reasoning)

• The Appellant had a trusted and significant role in large-scale, prolonged drug supply and money transportation; categorisation and sentencing figures adopted were appropriate given quantities and role.
• The prosecution had originally advanced a higher quantity in earlier proceedings; a 25% discount for plea (as applied) was appropriate given the post-adjournment acceptance of involvement at the reduced quantity.
• Sentences did not have to be concurrent; the totality principle required addressing the overall breadth of offending and cumulative criminality, including money laundering.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The court (Judge Holgate, agreeing with the single judge) analysed sentencing as follows:

• The Appellant's offending was prolonged, national in scale and involved significant quantities: at least 11 kg of cocaine, 603–608 kg of cannabis, large sums of cash (of the order of £1.6–1.8 million) and up to 116 kg of unspecified drugs. The Appellant acted as a trusted courier within an organised crime group's network.
• The sentencing judge identified appropriate category ranges for the drug offences (cocaine category 1, with an indicative amount of 5 kg and a starting point of 10 years; cannabis category 1 with an indicative amount of 200 kg and a starting point of 5 years 6 months) and adapted those to reflect the substantially larger quantities and the Appellant's role.
• The sentencing judge's reference to an 18-year figure for the cocaine offence was not a bare uplift solely to reflect 11 kg; it reflected the aggregate position once concurrent and consecutive elements, money laundering offending, and other uplifting features were taken into account. The court explained that treating the cocaine offence in isolation without regard to concurrent/consecutive and laundering sentences would have produced an inconsistent overall term.
• The judge expressly considered mitigating factors (including a psychiatric report diagnosing a moderate gambling disorder) and applied the totality principle when determining the overall sentence; reductions from hypothetical post-trial terms were applied to reflect guilty pleas (a 25% credit for the relevant plea scenario was accepted as appropriate).
• The single judge had earlier explained that the Appellant's earlier plea in the Magistrates' Court had been on a different basis (the prosecution initially argued a much larger quantity); after an adjourned Newton hearing the Appellant accepted involvement in 11 kg of cocaine and a 25% reduction was properly applied.
• Having regard to the money laundering offending, the substantial concurrent sentence for the cannabis offence, and the sustained nature of the offending, the court concluded that an overall sentence, before mitigation and plea credit, would have exceeded 20 years; after mitigation and credit a total of 15 years was within the range of reasonable and proportionate outcomes and was not manifestly excessive.

Holding and Implications

Leave to appeal refused.

Direct effect: the Crown Court sentence of 15 years' imprisonment, as imposed by Judge Jenkins and upheld by the single judge and by Judge Holgate in this opinion, remains in force. The court found no error in principle or that the sentence was excessive. The opinion does not establish a new precedent beyond affirming the application of the totality principle, assessment of plea credit in the factual context, and the treatment of concurrent and consecutive sentences in a case of aggregated offending.