Whilst the Criminal Justice Act 2003 s.285 had increased the statutory maximum sentence for causing death by dangerous driving that did not necessarily mean that the scale of every sentence, as set out in R v Cooksley (Robert Charles) (2003) EWCA Crim 996 , (2003) 2 Cr App R 18, had to be increased by 40 per cent.

[2005] EWCA Crim 1238