Singh, R. v

Factual and Procedural Background

This is an application by the Attorney General to bring a Reference under section 36 of the Criminal Justice Act 1988 on the basis that the Solicitor General considered the sentence to be unduly lenient. The opinion is delivered by Judge Dingemans.

The Defendant, aged 28, pleaded guilty on 11 September 2025 to three offences under section 18 of the Offences Against the Person Act 1861 (two counts of causing grievous bodily harm with intent and one count of wounding with intent). On 7 November 2025 at The Court he was sentenced: count 1 — 7½ years' imprisonment; count 2 — 5 years 3 months concurrent; count 3 — 3 years 9 months concurrent. The Defendant received 25% credit for plea.

The offending arose from an incident on 31 May 2025 at a pre-wedding celebration at Company A in The City. A Relative had been ejected after an altercation. The Defendant drove a vehicle along [Number] Main Street, mounted the pavement and struck a group of people, causing serious injuries to several persons (Victim A, Victim B, Victim C and Victim D). The Defendant left the scene, assaulted people, removed registration plates and attempted to mislead police about use of the vehicle. Victims sustained significant injuries requiring hospital treatment and continuing harm. Sentencing material included prosecution and defence notes, multiple victim personal statements and letters and prison reports relating to the Defendant's remorse and progress in custody.

Legal Issues Presented

1. Whether the sentence imposed on count 1 was unduly lenient such that the Attorney General's Reference should be allowed under section 36 of the Criminal Justice Act 1988.
2. Whether the sentencing judge failed adequately to apply the principle of totality in accounting for multiple offences and related aggravating factors when fixing the sentence on count 1.

Arguments of the Parties

Attorney Husbands' Arguments

• The starting point and sentence, although categorisations were correct, effectively reflected only a single offence.
• The judge failed adequately to apply the principle of totality and to take sufficient account of the multiple offences, the number of culpability factors and aggravating features (multiple injured victims, etc.).
• As a result, the overall sentence was insufficient and unduly lenient.

Attorney McClintock's Arguments

• The sentencing was a careful exercise; the categorisations and ranges used by the judge were correct.
• The judge expressly referred to totality and to the other counts; no error was made in approach.
• The Reference should be dismissed.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The court reviewed the sentencing judge's remarks to determine how the judge accounted for the other counts when fixing the sentence on count 1. The court accepted the categorisation of culpability (use of a car as a highly dangerous weapon placed the offences in the highest culpability category) and the harm gradings advanced by the judge, and noted the relevant aggravating and mitigating features set out to the judge (including previous convictions some ten years earlier, victims' vulnerability, presence of children on CCTV, leaving the scene, assaulting victims, attempts to mislead police, the Defendant's work and remorse, and progress in custody).

The court concluded that the judge's apparent uplift of approximately one year to reflect the other counts was plainly insufficient to reflect the totality of the criminality. The court performed its own exercise: it assessed count 1 as at the top of the range (10 years), deducted one year for mitigation (to 9 years), applied the 25% plea reduction (resulting in 6 years 9 months for count 1 alone), and then allowed a principled and proportionate uplift of 3 years 3 months to reflect the additional criminality from counts 2 and 3, reaching an overall sentence on count 1 of 10 years. Counts 2 and 3 were to remain concurrent.

The court also adjusted ancillary orders: the disqualification and extension periods required uplift. The extension period was recalculated as two‑thirds of a 10‑year sentence, namely 80 months (6 years 8 months), replacing the previously ordered extension of 5 years.

Holding and Implications

The Reference is allowed to the extent that the sentence on count 1 is increased from 7½ years to 10 years' imprisonment.

Counts 2 and 3 remain concurrent and unchanged. The vehicle disqualification and extension periods are adjusted so that the extension equals two‑thirds of the 10‑year sentence (80 months / 6 years 8 months). The decision changes the Defendant's effective custodial term and ancillary orders but does not purport to establish a new legal precedent beyond applying established principles for Attorney‑General References and the principle of totality.