Practice and Procedure

R v WAYNE ANTHONY FOX (2011)

PUBLISHED December 15, 2011
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[2011] EWCA Crim 3299

The imposition of a hybrid sentence comprising imprisonment for public protection and hospital and limitation directions under the Mental Health Act 1983 s.45A for offences of kidnapping and causing grievous bodily harm with intent was neither wrong in principle nor manifestly excessive where, although the offender had been suffering from an undiagnosed serious mental illness, criminal culpability was not wholly absent, and the degree of harm caused together with the significant risk to the public of future serious harm was also taken into account.

CA (Crim Div) (Davis LJ, Griffith Williams J, Lindblom J)

15/12/2011

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