Jhangha & Anor, R. v

Factual and Procedural Background

On 22 May 2025, two young defendants (hereinafter "Appellant A" and "Appellant B") pleaded guilty in the Crown Court to wounding with intent and possession of an article with a blade or point. On 10 October 2025, Judge Nawaz sentenced each appellant to six years and four months' detention in a young offender institution. The appellants sought renewed leave to appeal against sentence.

The offending arose from a series of gang-related incidents in The City over three consecutive days in July 2024 between Group A and Group B. The appellants travelled to The City to associate with Group A. On 24 July 2024, the appellants and others, armed with machetes, entered a private residence after confronting an occupant and demanded the whereabouts of a targeted individual ("Victim"). The Victim was repeatedly stabbed by members of the group, including the appellants, while another male prevented the victim's father from intervening by holding him at knife point. The Victim sustained very serious injuries requiring surgery and prolonged hospital treatment at The Hospital.

Appellant A's phone contained videos depicting the appellants with machetes; one machete was identified from doorbell footage as used in the attack. Appellant A made no comment in police interview; Appellant B provided a prepared statement denying the offending. Pre-sentence and psychological reports for both appellants described significant adverse childhood experiences, vulnerability, and developmental immaturity. Appellant B had been referred under modern slavery provisions and the National Referral Mechanism had produced a positive decision relevant to Appellant A.

Legal Issues Presented

1. Whether the sentencing judge erred in law or principle by adopting an adult starting point for sentence before reducing it to reflect the appellants' youth and immaturity.
2. Whether the judge was wrong to treat the offending as a joint enterprise making each participant equally responsible.
3. Whether the judge failed to give sufficient weight to material demonstrating the appellants' reduced educational development, maturity, and vulnerability to exploitation.
4. Whether the reduction applied to reflect youth (one third) and the credit for guilty plea were inadequate, rendering the sentences manifestly excessive or wrong in principle.

Arguments of the Parties

Appellant A's Arguments

• The judge misdirected himself by taking an adult starting point for sentencing a child/young person rather than applying the child guidelines directly.
• The judge erred in concluding equal responsibility for each participant in the joint enterprise.
• The judge failed to give adequate weight to evidence that his educational development and maturity were below his chronological age.
• The judge failed to give adequate weight to evidence of adverse experiences rendering him vulnerable to exploitation.
• The judge erred in not finding it unreasonable that the appellant did not enter an earlier guilty plea.

Appellant B's Arguments

• Adopted Appellant A's submissions.
• Accepted there was no criticism of the adult starting point used by the judge but argued the judge did not adequately examine the appellant's unique circumstances.
• Contended the judge did not explain why a one-third reduction for youth was chosen rather than a larger reduction (e.g. one-half).
• Argued the sentence of six years and four months was manifestly excessive when account was properly taken of vulnerability, exploitation findings and progress in custody.

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The court largely agreed with the single-judge refusals of leave. It emphasised the gravity of the offending: a very serious, group attack with machetes in a private home causing severe injuries to the Victim. Although the appellants were young and entitled to reductions for youth, the seriousness of their criminality required substantial punishment.

In relation to Appellant A (previously described in the opinion as Jobe), the court held there was no misdirection in identifying an adult starting point and then adjusting it for age and immaturity; the judge was entitled to treat the conduct as a joint enterprise and to attribute shared responsibility; the judge properly had regard to material on educational development, maturity and vulnerability; and the plea credit awarded was within the judge's permissible judgment.

In relation to Appellant B (previously described in the opinion as Jhangha), the court noted the sentencing judge expressly took into account the factors relied upon, including the positive National Referral Mechanism outcome and other vulnerabilities. The court observed that the precise quantum of reduction for youth is for the sentencing judge's judgment and concluded the one-third reduction applied was justified on the factors identified.

On the aggregate, the Court concluded neither renewed application raised an arguable case that the sentences were manifestly excessive or wrong in principle.

Holding and Implications

Both renewed applications for leave to appeal against sentence were REFUSED.

Implications: The direct effect is that the sentences of six years and four months' detention in a young offender institution imposed by Judge Nawaz remain in force for both appellants. The court did not establish any new legal principle; it affirmed the sentencing judge's exercise of discretion and concluded no arguable error of principle or manifest excess arose from the sentences imposed.