EWCA Crim 2017
A mandatory victim surcharge order could only be made where every offence for which the offender had been sentenced was committed after October 1, 2012. If one of the offences was committed before that date a surcharge could only be imposed if the sentence included a fine. Accordingly, a victim surcharge had been unlawfully made where it related to one offence before that date and four offences after.
CA (Crim Div) (Henriques J, Blake J)