Buhari, R. v

Factual and Procedural Background

This appeal arises from a trial in The Crown Court at The City before Judge Spencer in which the Appellant was convicted, on 4 August 2023, of two counts of murder. Two victims (Victim 1 and Victim 2) died in a high-speed car crash on 11 February 2022 following a coordinated pursuit by two other vehicles. Eight persons were implicated. Several co-defendants were convicted of murder or manslaughter and received custodial sentences; one co-defendant was acquitted of all counts. On 1 September 2023 the trial judge imposed life sentences with specified minimum terms for those convicted of murder. On 24 October 2025 this court allowed an appeal against sentence brought by one co-defendant (recorded at [2025] EWCA Crim 1353) and reduced that co-defendant's minimum term. The Appellant sought an extension of time (780 days) to apply for leave to appeal her sentence; that application was referred to the full court by the Registrar.

Legal Issues Presented

1. Whether the Appellant should be granted a long extension of time to seek leave to appeal against her sentence.
2. If an extension is granted, whether leave to appeal against the Appellant's minimum term should be granted and the minimum term reduced.

Arguments of the Parties

Appellant's Arguments

• The recent successful reduction of a co-defendant's minimum term ([2025] EWCA Crim 1353) resulted in a minimum term only one year greater than that imposed on the Appellant despite the trial judge finding the Appellant's degree of planning was significantly less; this comparative disparity should weigh in favour of granting the extension and leave to appeal.
• The trial judge may have applied an inappropriate upward adjustment to the Appellant's minimum term influenced by the error in the co-defendant's sentence.
• The judge failed to give sufficient weight to mitigating matters specific to the Appellant, including the history of blackmail by Victim 1 and a range of factual points indicating limited involvement and lack of leadership in the offending.
• The minimum term is submitted to be manifestly excessive and should be reduced if leave is granted.

Table of Precedents Cited

Court's Reasoning and Analysis

The court reviewed the factual matrix accepted at trial: coordinated pursuit of the victims' vehicle, high speeds, a collision consistent with being rammed from behind, the Appellant's place among a group that had planned to confront Victim 1, and the prosecution's reliance on communications, telematics, forensic collision evidence and other material. The court accepted that the sentencing starting point for two murders under section 321 of the Sentencing Act 2020 and Schedule 21 paragraph 3 was 30 years.

The court considered the Appellant's submissions in the light of the co-defendant's successful appeal ([2025] EWCA Crim 1353) and the reasoning there that youth and immaturity had been under-weighted. The court concluded that that reasoning could not assist the Appellant because she was an older adult and the sentencing judge had specifically found her to be the mature adult in the group.

The court analysed whether any underweighting of mitigation in the co-defendant's case had produced an unjust upward effect on the Appellant's sentence. It rejected that contention, finding that the trial judge had correctly fixed the statutory starting point and undertaken an individual assessment of aggravating and mitigating factors for each offender. The court acknowledged the Appellant's comparative lack of planning but concluded the sentencing judge had already taken that into account. The court also found that the evidence of the Appellant's post-incident conduct did not demonstrate significant remorse and that the background of blackmail provided only limited mitigation which had been adequately considered.

Having reviewed all points advanced on behalf of the Appellant, the court concluded that the minimum term properly reflected the Appellant's role as a central figure in the events and that the matters relied upon did not justify an extension of time or leave to appeal.

Holding and Implications

REFUSED: The application for an extension of time to seek leave to appeal and the application for leave to appeal against sentence are refused.

Direct effect: The Appellant's sentence, including the imposed minimum term (life imprisonment with the specified minimum term as fixed by the trial judge), stands unaltered.

No broader or novel legal principle was established by this decision; the court applied existing sentencing law and affirmed the individual assessment carried out by the trial judge.