The Covid-19 pandemic continues to pose a series of challenges to the criminal justice system. The sentencing regime is no exception. In R v Manning [2020], the Court of Appeal established that prison conditions could and should be factored into decisions to suspend custodial terms where appropriate, setting in motion a series of higher courts’ decisions on the availability and scope of the ‘Covid Discounts’.

More than a year on, the Court has now fine-tuned its earlier jurisprudence; this article examines the implications of R v Dixon [2021] for offenders, advocates and sentencers concerned with Covid-related submissions at sentencing.

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