Greg Unwin Successfully Resists Attorney General’s Reference to the Court of Appeal

9 April 2026

The defendant received an 11-year aggregate sentence for a “brutal” kidnap and Class A drugs conspiracy. The Solicitor General, represented by Senior Treasury King’s Counsel, argued this was unduly lenient, specifically targeting the judge’s reduction of the consecutive drugs sentence from a 7-year starting point down to 2 years to reflect totality.

Greg Unwin argued that rather than focus on mechanics of the totality reduction the court should evaluate the justice and proportionality of the aggregate sentence. It was a severe punishment for a young, first-time offender with significant personal mitigation, and not unduly lenient within the meaning of the authorities.

The Court of Appeal agreed, finding that while the reduction to the drugs sentence for totality was “very substantial”, the overall 11-year sentence was not unduly lenient, noting the requirement in section 231(2) of the Sentencing Act 2020 that a custodial sentence

must be the shortest sentence commensurate with the seriousness of the offending. Paragraph 35 of the judgment contains a helpful list of five leading authorities with paragraph references, useful for practitioners dealing with Attorney General’s references.

These cases make it clear that a sentence is only unduly lenient if it falls entirely outside the range a trial judge could reasonably consider appropriate. The reference procedure aims to correct “gross errors” and preserve public confidence, rather than to adjust borderline cases or make minor sentence increases. Appellate courts recognise sentencing as an art, deferring to the trial judge’s assessment of competing factors. Judges may depart significantly from guidelines where justified by the facts or mitigation. In such cases, leniency is “commended not condemned”, and appellate intervention is reserved exclusively for exceptional circumstances.

Mohammed; Ahmed [2026] EWCA Crim 389

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