Ibrahim Khan [2019] EWCA Crim 1202

The appellant was committed for sentence following guilty pleas to having false registration plates, dangerous driving, failing to stop for a police officer and driving without a licence and insurance. He was sentenced to 4 months detention for the false plates with a consecutive sentence of 10 months for dangerous driving.

The appellant bought the car and suspected it was stolen, although it was not, he said that the false plates were already on it. When officers tried to stop the car the appellant made off, pursued by the police in a pursuit lasting between 30 and 60 seconds before the car stopped and the occupants tried to run off.

Held: it was understood why immediate custody was required and that consecutive sentences should be imposed.

“However, in imposing a sentence the court is required to determine the shortest sentence commensurate with the combination of offences. Where it is appropriate to pass consecutive sentences the totality guideline requires that the court considers if the aggregate is just and proportionate and, if not, to take steps by either reducing the individual sentences to achieve proportionality or, in appropriate cases, imposing no separate penalty for some.”

The sentence for dangerous driving was reduced to 8 months and that for false plates to 2 months, making a total of 10 months detention.