The Court of Appeal has increased the sentence of Dale Hamilton, 30, from 10 to 13 years following a referral by the Solicitor General under the Unduly Lenient Sentence (ULS) scheme. Hamilton was originally sentenced at Teesside Crown Court on 11 August 2025; the appeal court ordered the increase on 9 December 2025.
According to the Attorney General’s Office, Hamilton ran a cocaine supply line in 2024 and targeted a neighbour who was a former police officer and recovering addict by posting cocaine through their letterbox. He later threatened the neighbour with a zombie knife, took over the victim’s flat, demanded money, and made threats to kill. A driver who worked for him was also extorted and threatened, including threats to shoot the driver’s children.
In remarks released with the decision, the Solicitor General, Ellie Reeves MP, welcomed the outcome and commended the victims for coming forward, describing Hamilton as dangerous and violent. The Attorney General’s Office confirmed the uplift followed an assessment that the original term was unduly lenient.
The ULS scheme allows the Law Officers to ask the Court of Appeal to review certain Crown Court sentences within 28 days. The power is set out in section 36 of the Criminal Justice Act 1988; with the court’s leave, the original sentence can be quashed and a new sentence imposed within the powers available to the sentencing court.
Only offences within the scheme are eligible, typically indictable‑only crimes and others added by order. Where at least one offence is in scope, the Court of Appeal can review all sentences passed in the case. Timeliness is strict: a referral must be made within 28 days of sentence.
Recent management information published by the Attorney General’s Office shows that between January and March 2025, the Court of Appeal increased 33 of 48 sentences considered under the ULS scheme, with nine of those cases relating to drug offending. The AGO publishes a weekly update of outcomes alongside annual datasets for longer‑term trends.
For victims and practitioners, the process is accessible and time‑limited. Members of the public can request ULS consideration online; prosecutors prepare reports for the Law Officers; and the Court of Appeal assesses whether the sentence fell outside the reasonable range. The court generally confines itself to material before the sentencing judge when deciding undue leniency, though it may consider additional material when deciding whether to exercise its discretion to increase. The traditional ‘double jeopardy’ concern is no longer taken into account as a matter of course.
Hamilton’s case underlines that ULS references are used across offence types beyond sexual and homicide cases, including serious drug offending combined with robbery, kidnapping and blackmail. While the threshold remains high, the mechanism provides a route to correct sentences that fall outside the range reasonably available to the original judge.