R v Steel
| Jurisdiction | England & Wales |
| Judgment Date | 15 July 1992 |
| Date | 15 July 1992 |
| Court | Court of Appeal (Criminal Division) |
Court of Appeal, Criminal Division
Road traffic - reckless driving - consequences relevant for sentencing
In cases of reckless driving the consequences as well as the quality of the driving were relevant when determining the appropriate sentence.
The Court of Appeal, Criminal Division (Lord Justice Lloyd, Mr Justice Tudor Evans and Mr Justice Latham) so held on July 9 in allowing an appeal by Mark Jonathan Steel against a sentence of 15 months imprisonment imposed in January 1992 at Reading Crown Court (Judge Spence) for reckless driving and reducing it to 12 months.
MR JUSTICE TUDOR EVANS said that there was a clear distinction between cases where personal injury was caused by an error amounting to careless driving and cases where such injury was caused by reckless driving. That was shown by the nature of the offence and the state of mind of the offender in a case of reckless driving. Unforeseen consequences might be relevant (R v KrawecUNK (1984) 6 CrAppr (S) 367)).
In the Court of Appeal's view, when...
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R v Hugh Shaw
...convicted of dangerous driving will be sent to prison at all. But as has been made plain by this Court in R v Mark Jonathan Steel 96 Cr App R 121, one of the factors which a sentencing court has to have regard to when sentencing for dangerous driving is the likely consequences and the actua......
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