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Sentencing guidelines and Parliament: building a bridge - Justice Committee Contents


3  Democratic and judicial voices

19. The role that Parliament plays in monitoring sentencing guidelines has to take into account the different roles of Parliament and the judiciary. While sentencing as a whole requires democratic legitimacy, justice in individual cases requires that the independence of judicial decision-making is beyond question. This chapter explores these areas to inform the future of parliamentary monitoring of sentencing guidelines.

THE MANY INFLUENCES ON A SENTENCE

20. The decision as to what sentence to impose is a balance between the influence of the individual sentencer and the framework set by Parliament. Professor Neil Hutton, University of Strathclyde, comments:

    "There is a common misconception that judges have sole authority over sentencing decisions; this is never the case even in those jurisdictions where judges exercise very wide discretion. Sentencing always takes place within a legally authorised structure."[23]

21. The overarching division between the role of Parliament and the role of the sentencer is that one (Parliament) defines the framework for sentencing where the other (the sentencer) makes the decision on the individual case within that framework. The former Lord Chief Justice, Rt Hon Lord Phillips of Worth Matravers, described the balance of interests:

    "The primary way that Parliament influences the sentence is by making statutory provisions that restrict the discretion of the judge as to what sentence to impose. The most obvious example is that when a new offence is introduced by statute the statute will normally specify the maximum sentence that the judge can impose. In this way Parliament indicates its view of the relative gravity of the offence and the judges have regard to this when imposing individual sentences."[24]

22. Parliament defines the overall sentencing framework by setting maximum penalties for offences and determining the structures of sentencing, for example defining in legislation that a court must take a guilty plea into account when determining sentence or by legislating for specialised types of sentence or sentencing, such as Imprisonment for Public Protection (IPP) sentences for those offenders considered to be dangerous.[25] Our Towards Effective Sentencing inquiry considered in detail Government failures to provide adequate resources for the implementation of IPP sentences and concerns about how these sentences were originally designed in the Criminal Justice Act 2003.[26]

23. There are also a great many other factors that affect what sentences are imposed and what they mean in practice. Local policing priorities or public willingness to report crime will affect whether a person ever enters the criminal justice system in the first place; the Crown Prosecution Service decision as to what offence a person should be charged with determines which of the maximum sentences set by Parliament the sentencer is working with. Once a sentence is imposed, the operation of that sentence will depend significantly on decisions made by the services responsible for implementation. For example, for prisoners on IPP sentences, the type of sentence and the minimum sentence will have been determined by the sentencer but it is the Parole Board who will decide how long that individual spends in prison beyond the minimum term. Nicola Padfield, University of Cambridge, referred to factors like this as "back-door" sentencing, saying: "It is too easy to lay the blame on magistrates and judges."[27]

JUDICIAL DISCRETION

24. Rt Hon Lord Judge, Lord Chief Justice, emphasised the principle of judicial discretion to the Justice Select Committee: "The point about the judicial discretion is that a judge is trying to do justice in the individual case".[28] However, the judge's ability to respond to the individual case takes place only within the range of influence that his or her decision can have and according to the framework set by Parliament. Where proposals come forward that might move decisions about sentencing into the hands of Parliament, the Magistrates' Association raise misgivings about "upsetting the balance between the legislature and the judiciary."[29] The Council for HM Circuit Judges fear the consequences of such action: "executive or legislative encroachment would put the separation of powers at risk undermining the Constitution."[30] The Criminal Bar Association commented on how judicial discretion is integral to the criminal justice system:

    "Judges must be allowed to retain a discretion to decide upon a sentence that is appropriate for the particular facts of an individual case. The exercise of this discretion, based upon a full consideration of the individual case, is exactly the judgment that a judge is expected to bring to the criminal justice system."[31]

25. Sentencing guidelines fall inbetween the exercise of discretion by individual sentencers and the overall framework drawn up by Parliament, by providing further guidance to sentencers on levels of seriousness within an offence type and how that translates into sentence types and lengths. The Sentencing Guidelines Council, responsible for the final decision as to what instructions go into these guidelines to sentencers, is chaired by the Lord Chief Justice and has a majority of judicial members; guidelines are drawn up with reference to current patterns of sentencing and guideline judgments from the Court of Appeal. The Sentencing Guidelines Council is thus an independent body with significant judicial input. We look in more detail at what the Sentencing Guidelines Council focuses on when drawing up guidelines later in this report.

26. Professor Mike Hough, King's College London, suggested that there is a general consensus of support for current sentencing guidelines produced by the Sentencing Guidelines Council. He said: "We have talked to judges and magistrates about their sentencing practice, including their views of the guidelines, and I do not get a sense that they find them appalling."[32] The reason that there is support for sentencing guidelines seems to be, according to practitioners and academics, that they provide an appropriate balance between discretion for the individual case and a consistent structure for decision making. The Magistrates' Association, for example, commented:

    "It [the Consultation Sentencing Guideline for Offences Against the Person] is certainly designed—all guidelines are—to improve consistency of approach. As far as outcome is concerned, it is inevitable that there will be a range depending on the individual circumstances."[33]

Professor Andrew Ashworth QC, Oxford University, said:

    "[The current approach to sentencing guidelines] allows judges room for manoeuvre, it allows them to go outside the range if there is something unusual, but it should require them to start from a certain point in all similar cases."[34]

A DEMOCRATIC DEFICIT?

27. The role of Parliament in sentencing policy is the "democratic expression of the 'public voice'".[35] Whereas some witnesses said the guidelines allow judicial discretion, there are concerns that mechanisms for drawing them up leave a 'democratic deficit'.

28. Warren Young and Claire Browning of the New Zealand Law Commission argue that, without parliamentary participation in drawing up sentencing guidelines:

    "there is no effective mechanism whereby Parliament can participate in the setting of sentencing levels and thereby perform its social policy function. If it wishes to try, it has recourse only to the blunt tool of amending maximum penalties, in the hope that this will have some unspecified trickle-down effect upon sentencing in the ordinary run of case."[36]

The New Zealand Law Commission therefore proposed that a new sentencing body in New Zealand should draw up sentencing guidelines and then place them before Parliament in their entirety subject to a negative resolution procedure.[37] They felt that, if the:

    "goal of changing the nature of the law and order debate is to be achieved, there must be some political ownership of the [sentencing] guidelines […]. The alternative is that it is too easy to use sentencing as a rhetorical political device." [38]

29. The Sentencing Commission Working Group considered whether, in creating a new sentencing body, changes should be made to how Parliament considers sentencing guidelines; the Working Group was unable to agree. A minority of the Sentencing Commission Working Group recommended, as had been the proposal for New Zealand, that Sentencing Guidelines should be placed before Parliament to be accepted or rejected as a whole. It commented that "enhancing Parliamentary scrutiny and participation in the guidelines process would give the guidelines greater democratic legitimacy".[39] It also commented on the impact of a formal process of parliamentary approval on the quality of public debate over sentencing:

    "such a system may lead to stability over time. It would reduce the risk that sentences would increase in response to political criticism of individual decisions and would help to control the impact of media firestorms. Parliament might be encouraged to take responsibility for the guidelines in the knowledge of the price tag attached to them."[40]

30. Sentencers in England and Wales are sceptical about Parliament as a venue for rational debate on law and order. The Judiciary of England and Wales commented on New Zealand proposals for laying sentencing guidelines before Parliament:

    "The principal advantage claimed is this allows elected members of Parliament to participate in the setting of sentencing levels, which may be thought to be a matter of legitimate social concern: it would be a way of giving some form of Parliamentary 'ownership' to the advisory guidelines of the Council. […] The risk must be that it will allow sentencing levels to be driven up yet further by tabloid pressure and political rhetoric."[41]

The Council of HM Circuit Judges quoted the former Lord Chief Justice, Rt Hon Lord Woolf, as saying:

    "We should at all costs avoid the House of Commons becoming involved in a bidding war about sentencing levels in which someone argues for a standard sentence of one year for a first time burglar and someone else suggests two and someone else suggest three".[42]

31. Our two academic witnesses had similar concerns about whether Parliament could consider sentencing without "politicians [being] locked in a counterproductive battle to 'out-tough' each other."[43] Professor Ashworth expressed concern that Parliament as a whole might look at sentencing guidelines, saying:

    "I have a certain reluctance simply borne of the possibility that perhaps some Members of Parliament might, for their own reasons or for reasons of things that have happened in their constituency, feel that they have to argue in favour of severity all the time, and it would also, I think, put the Government on the spot because they would have to decide where their position was on any particular guideline or set of guidelines".[44]

Professor Hough had similar concerns, but nevertheless concluded that sentencing guidelines should be placed before Parliament. He stated:

    "it is very important to have some sort of buffer institution to stand between sentencing and the law and order rhetoric that one inevitably gets between Parliament and the press; but on the other hand to have no parliamentary oversight at all is unthinkable."[45]

Professor Hough and Jessica Jacobsen recommended, in their report Creating a Sentencing Commission for England and Wales: an opportunity to address the prison crisis, that sentencing guidelines be presented to Parliament on a negative resolution procedure. They propose this as an addition to the Justice Select Committee reviewing guidelines.[46]

32. The recommendation made by the majority of the Sentencing Commission Working Party was that sentencing guidelines should not be laid before Parliament for approval, regarding this as "a significant and unwarranted change in the relationship between Government and Parliament on the one hand and the judiciary on the other. They [those members of the working group making this recommendation] believe that seeking Parliamentary approval would inevitably result in the politicisation of the guidelines."[47] A comment was nevertheless made that "consideration might be given to enhancing Parliament's existing role in scrutinising draft guidelines."[48]

The role of the Justice Select Committee

33. The current role of the Justice Select Committee is seen as an appropriate balance between judicial independence and democratic scrutiny, in the sense that the Justice Select Committee comments on draft guidelines, but our views are not binding on the Sentencing Guidelines Council. The Council of HM Circuit Judges said:

    "We agree that the present procedure which provides that Parliament and Ministers should be consulted […] is appropriate […]. We believe that the Sentencing Guidelines Council, as an independent body, should make the final decision".[49]

Professor Ashworth similarly was satisfied with the role of the Justice Select Committee, concluding, "so for myself I am very happy with the job that this Committee does."[50]

34. Whilst maintaining this balance, our experience of monitoring sentencing guidelines in our first two years as the Justice Select Committee has suggested ways in which this role might be enhanced. These include ensuring cross-fertilisation between review of individual guidelines and scrutiny of the broader criminal justice context, and using consideration of sentencing guidelines to enhance post-legislative scrutiny.

SETTING A SENTENCING GUIDELINE IN CONTEXT

35. Professor Ashworth raised a concern about how looking at individual areas in terms of sentencing guidelines can skew effective oversight:

    "the fact that the guidelines at the moment come out in penny numbers […] does not really lend itself to a proper rounded consideration of the whole map and that is really what now above all we need to do. […] the fact that we proceed at the moment by penny numbers not only inhibits proper parliamentary scrutiny but also gives that press regular field days because they can have a little pick at each guideline […] whereas it would be far better if they looked at the whole picture."[51]

36. Our consideration of an individual sentencing guideline often raises issues of the inter-relationships between sentencing for different offences. For example, RoadPeace questioned the relationship between offences of causing death by driving and those offences which involve the same standard of driving but, by fortune, no fatality. They stated: "the maximum sentence is 14 years if the victim happens to be killed, but just two years for an act of equally bad driving if the victim happens to survive (even if s/he is maimed for life)."[52]

37. We have also seen how key conundrums for sentencing as a whole may be highlighted through an individual sentencing guideline. The sentencing guideline for theft and burglary not in a dwelling raised issues of dealing with persistent low level offenders, including those stealing to fund an addiction. Paul Cavadino, Chief Executive of Nacro, suggested that there was a double-standard in sentencing such individuals:

    "we tend to say, 'we have tried fines and we have tried community penalties. They did not work. Therefore, we must use custody'. We less often say, 'We have used custody. The offender re-offended. That did not work, so we ought to try something else'."[53]

He went on to argue that, as with individuals who have to try to give up smoking several times before they succeed, a drug addict may require more than one chance. He spoke of people in his experience: "They have gone on a drug rehabilitation programme, they have relapsed, they have re-offended, but they have subsequently had another chance. They have gone on another programme and eventually have succeeded."[54] He concluded that "we should be ready, in appropriate cases, to use community penalties of an appropriate kind repeatedly, if that seems to be the best option, the option most likely to prevent re-offending."[55]

38. An important aspect of our work with sentencing guidelines has therefore been to pinpoint concerns about the broader aspects of the criminal justice system during consideration of individual guidelines. In considering sentencing for offences against the person, we asked questions about the use of custodial sentences for less serious violence. In relation to sentencing for theft, we looked at cases where individuals commit crimes to fund an addiction, and how a sentencing regime can respond effectively to an individual who may find it difficult to move past that addiction and out of crime. Sentencing for offences of causing death by driving raised a number of issues around how bereaved families are kept informed about criminal justice processes. Where relevant, we have commented on these both to the Sentencing Guidelines Council and the Ministry of Justice. We have further found that the focus on an individual area of sentencing provided important considerations for our scrutiny in other areas. For example, we were able to take ideas from Victim Support on what victims want from the criminal justice system, discussed in the context of the sentencing guideline on theft and burglary (non-dwelling), and pursue these with witnesses in our Justice Reinvestment inquiry.[56]

39. Consideration of sentencing guidelines is an unusual parliamentary process without applicable formal parliamentary procedures. It also presents certain practical difficulties. It has not been possible, for example, within the usual guidelines timetable to conduct conventional select committee evidence gathering leading to a report to the House. Whereas normally a select committee determines its own priorities as to where scrutiny is important, the process of monitoring sentencing guidelines is subject to the timetables and processes of an external body, the Sentencing Guidelines Council, which itself may be affected by timetables for implementing new criminal offences. These timetable pressures particularly affect the range of evidence available to us, as the most relevant organisations may also be seeking to respond on specific issues relating to the guideline directly to the Sentencing Guidelines Council.[57]

CONTRIBUTING TO POST-LEGISLATIVE SCRUTINY

40. The Lords Constitution Committee commented in their report Relations between the executive, the judiciary and Parliament on the desirability of post-legislative scrutiny, which could look at how courts are interpreting and applying legislation.[58] Our experience with sentencing guidelines has suggested that consideration of sentencing guidelines, which are after all a concrete example of a system explicitly designed to provide more practical information on the application of legislation, provides indications of where post-legislative scrutiny may be important.

41. One overarching issue that has arisen during our scrutiny of sentencing guidelines is the complexity of the criminal law. Nicola Padfield, University of Cambridge, described for the Committee one of the challenges facing sentencers:

    "the law rightly says and completely properly says, you get sentenced on the law which applied when you did your crime. This means we cannot just learn the law today, we have to know yesterday's, and the day before, and people are being released under systems for crimes they committed and were sentenced for a few years ago."[59]

She concluded:

    "We live in a nightmare world of criminal justice. I had not thought I was going to say this but maybe it is an opportunity to say yet again, yes, we do need a criminal code and we do need a sentencing code and a code of criminal procedure."[60]

The Magistrates' Association were also interested in simplification of criminal legislation, although sceptical that it could be achieved effectively: "Please, no more Acts, no more legislation. Although in principle codification would be wonderful, I do not think it would be done in the way that everybody would wish."[61]

42. Scrutiny of guidelines might also suggest the need for post-legislative scrutiny of a particular area of legislation. CTC, the national cyclists' organisation, commented on the draft guideline for offences of causing death by driving: "The draft SGC [Sentencing Guidelines Council] guideline proposals are generally sensible given the legal anomalies within which they must operate."[62] One potential issue with the legal framework was brought to light by public opinion research commissioned by the Sentencing Advisory Panel on sentencing for these offences. The sentencing guideline for Causing Death by Driving covers four offences:

  • Causing death by dangerous driving (maximum 14 year custodial sentence);
  • Causing death by careless driving whilst under the influence of alcohol or drugs (maximum 14 year custodial sentence);
  • Causing death by careless driving (maximum five year custodial sentence);
  • Causing death by driving: unlicensed, uninsured, disqualified (maximum two year custodial sentence).

The maximum sentences set in legislation may suggest a hierarchy of seriousness for the offences, with the longest maximum sentence the most serious. In research focus groups people distinguished between a deliberate choice to drive whilst disqualified where somebody died, even if the standard of driving was not in question, and careless driving where someone died, which was conceptualised as a tragic error.[63] There is therefore a potential mismatch between public and legislative assessment of seriousness in these offences.

43. A further element to sentencing guidelines and post-legislative scrutiny is the extent to which a sentencing guideline accords with legislative intention. The Sentencing Guidelines Council is required to consider when drawing up guidelines:

a)  the need to promote consistency in sentencing,

b)  the sentences imposed by courts in England and Wales for offences to which the guidelines relate,

c)  the cost of different sentences and their relative effectiveness in preventing re-offending,

d)  the need to promote public confidence in the criminal justice system, and

e)  the views communicated to the Council […] by the [Sentencing Advisory] Panel. [64]

We have found consistently when reviewing different sentencing guidelines that the cost and relative effectiveness in preventing re-offending of different sentences and the need to promote public confidence in the criminal justice system present difficulties. We consider further in chapter four issues relating to these. We hope that over time our scrutiny of sentencing guidelines will contribute to the broader debate of how to reach effective sentencing solutions, thereby meeting the expectations of Parliament, victims and the public.

44. Parliament sets the framework for sentencing in legislation. Sentencing guidelines are a key element to how this legislation works in practice. It is vital that Parliament, representing the public voice, contributes to sentencing guidelines as they are produced and in doing so identifies the crucial issues of public confidence and the effectiveness of sentencing. We are convinced this is compatible with safeguarding the crucial discretion of sentencers to impose a sentence tailored to the individual case.

45. We are concerned that, all too often, political debates about sentencing descend into a counter-productive competition as to who can appear toughest on crime, measured by sentence length. A select committee works on the basis of consensus and we are less likely to fall foul of the temptation to 'out-tough' each other in our consideration of sentencing guidelines or to confuse length of sentence with effectiveness.

46. On the basis of our experience with sentencing guidelines, we have found that a spotlight on an individual sentencing guideline can illuminate broader concerns and issues in relation to the criminal justice system. We will continue to review sentencing guidelines in the wider context, seeking thereby to enhance the quality of scrutiny of criminal justice policy and legislation. This is an entirely different process from judgments on individual cases.


23   Hutton, N. 'Institutional Mechanisms for incorporating the public',in Frieburg A., and Gelb K. (eds), Penal Populism, Sentencing Councils and Sentencing Policy, Willan Publishing, Devon, 2008, p208 Back

24   Rt Hon Lord Phillips of Worth Matravers, "Who decides the sentence?", Prisoners' Education Trust Annual Lecture, 14 October 2008

Rt Hon Lord Woolf was Lord Chief Justice 6 June 2000-30 September 2005; Rt Hon Lord Phillips of Worth Matravers was Lord Chief Justice 30 September 2005-1 October 2008, during which time he gave evidence to the Home Affairs Select Committee as part of the Towards Effective Sentencing inquiry; Rt Hon Lord Judge has been Lord Chief Justice since 1 October 2008, when he was also elevated to the peerage, but gave evidence to the Justice Committee prior to this as President of the Queen's Bench Division and Head of Criminal Justice. Back

25   Criminal Justice Act 2003, section 144 Back

26   Justice Committee, Fifth Report of Session 2007-08, Towards Effective Sentencing, HC 184-i Back

27   Oral Evidence taken before the Justice Committee on Sentencing Guidelines, 22 January 2008, HC (2007-08) 279-i, Q 4  Back

28   Oral Evidence taken before the Justice Committee on Sentencing Guidelines, 22 January 2008, HC (2007-08) 279-i, Q 19 Back

29   The Magistrates' Association Response to the Sentencing Commission Working Group Consultation, 30 May 2008 Back

30   Council of HM Circuit Judges Response to the Sentencing Commission Working Group Consultation, 30 May 2008  Back

31   Criminal Bar Association Response to the Consultation Paper of the Sentencing Commission Working Group, 5 June 2008  Back

32   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 23 Back

33   Oral Evidence taken before the Justice Committee on Draft Sentencing Guidelines: Assaults, 23 October 2007, HC (2006-07) 1098-i, Q 2 Back

34   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 21 Back

35   Hutton, N. 'Institutional Mechanisms for incorporating the public', in Frieburg A., and Gelb K. (eds), Penal Populism, sentencing Councils and Sentencing Policy, Willan Publishing, Devon, 2008, p210 Back

36   Young, W. and Browning, C., 'New Zealand's Sentencing Council', Criminal Law Review, No. 4 (2008) Back

37   Since the 2008 election in New Zealand proposals for a new Sentencing Council have not been progressed. Back

38   Young, W. and Browning, C., 'New Zealand's Sentencing Council', Criminal Law Review, No. 4 (2008) Back

39   Sentencing Commission Working Group, Sentencing Guidelines in England and Wales: An Evolutionary Approach, July 2008, paragraph 8.21 Back

40   Sentencing Commission Working Group, Sentencing Guidelines in England and Wales: An Evolutionary Approach, July 2008, paragraph 8.22 Back

41   Response prepared at the request of the Senior Presiding Judge, Response to the Sentencing Commission Working Group Consultation Paper, 30 May 2008  Back

42   Council of HM Circuit Judges, Response to the Sentencing Commission Working Group Consultation, 30 May 2008  Back

43   Hough, M., Jacobsen, J. and Prison Reform Trust, Creating a Sentencing Commission for England and Wales: an opportunity to address the prison crisis, 2008  Back

44   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 37 Back

45   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 38 Back

46   Hough, M., Jacobsen, J. and Prison Reform Trust, Creating a Sentencing Commission for England and Wales: an opportunity to address the prison crisis, 2008  Back

47   Sentencing Commission Working Group, Sentencing Guidelines in England and Wales: An Evolutionary Approach, July 2008, para 8.23 Back

48   Sentencing Commission Working Group, Sentencing Guidelines in England and Wales: An Evolutionary Approach, July 2008, paragraph 8.26 Back

49   Council of HM Circuit Judges, Response to the Sentencing Commission Working Group Consultation, 30 May 2008  Back

50   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 37 Back

51   Oral Evidence taken before the Justice Committee on the Sentencing Commission, 14 October 2008, HC (2007-08) 1095-i, Q 37 Back

52   Justice Committee, Consultation Sentencing Guideline: Causing Death by Driving, Oral and Written evidence, 4 March 2008, HC (2007-08) 407-i, Ev 17 Back

53   Oral evidence taken before the Justice Committee on Consultation Sentencing Guideline: Theft and Burglary (non-dwelling), 3 June 2008, HC (2007-08) 649-i, Q 11 Back

54   Oral evidence taken before the Justice Committee on Consultation Sentencing Guideline: Theft and Burglary (non-dwelling), 3 June 2008, HC (2007-08) 649-i, Q 11 Back

55   Oral evidence taken before the Justice Committee on Consultation Sentencing Guideline: Theft and Burglary (non-dwelling), 3 June 2008, HC (2007-08) 649-i, Q 11 Back

56   See for example, uncorrected transcript of oral evidence taken before the Justice Committee on Justice Reinvestment, 24 June 2008, HC (2007-08) 425-iv, Q171 Back

57   On 20 May 2009 the House agreed changes to its Standing Orders to enable parliamentary scrutiny of National Planning Statements. This procedure has some similarities with the consideration of draft sentencing guidelines such as external timetabling pressures. Back

58   House of Lords, Report of the Select Committee on the Constitution, Relations between the executive, the judiciary and Parliament, Session 2007-08, HL Paper 177 Back

59   Oral Evidence taken before the Justice Committee on Sentencing Guidelines, 22 January 2008, HC (2007-08) 279-i, Q 14 Back

60   Oral Evidence taken before the Justice Committee on Sentencing Guidelines, 22 January 2008, HC (2007-08) 279-i, Q 14 Back

61   Oral Evidence taken before the Justice Committee on Draft Sentencing Guidelines: Assault, 23 October 2007, HC (2006-07) 1098-i, Q 27 Back

62   Justice Committee, Consultation Sentencing Guideline: Causing Death by Driving, Oral and Written evidence, 4 March 2008, HC (2007-08) 407-i, Ev 21 Back

63   Justice Committee, Consultation Sentencing Guideline: Causing Death by Driving, Oral and Written evidence, 4 March 2008, HC (2007-08) 407-i, Q 27 Back

64   Criminal Justice Act 2003, Section 170 Back


 
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