Court of Appeal Upholds Minimum Term in Drug-Related Murder Case

On 4 September 2025, in the Court of Appeal, Richard Barraclough KC appeared on behalf of the Crown in the case of R v Qasim, opposing an appeal against the minimum term of 30 years imposed by the trial judge in Birmingham for a murder arising from a drug gang dispute.

The appellant, who was 22 years old at the time of the offence, argued that insufficient weight had been given to his youth and immaturity during sentencing, when balanced against the aggravating factors of planning and disposal of the weapon.

The Crown submitted that the trial judge had taken proper account of age and immaturity, but that these factors were rightly offset by the deliberate and organised nature of the offending. The Court accepted the Crown’s submissions, noting that the appellant’s conduct demonstrated a level of maturity and culpability inconsistent with a substantial reduction for youth.

The appellant was found to have:

• Played a central role in luring the victim to the scene of the attack;
• Armed himself intending to inflict at least grievous bodily harm;
• Used the knife, removed drugs from the victim’s car, and disposed of the weapon;
• Led his accomplices through a pre-planned escape route, changing clothes to disguise themselves; and
• Left the jurisdiction following the murder, returning later when he considered it strategically advantageous.

At trial, he denied involvement, claiming to be an innocent bystander and suggesting that the victim had accidentally stabbed the deceased.

The appellant sought to rely on R v ZA [2023] EWCA Crim 596, which emphasised the developing nature of the adolescent brain and its relevance to culpability. However, the Court distinguished that case, observing that R v ZA was not a murder case and that the statutory framework under Schedule 21 already accounts for age. While some degree of immaturity may justify a lower starting point, the Court found no evidence of particular immaturity in this case.

The appeal was accordingly dismissed, and the 30-year minimum term was upheld.