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R v Bohannan [2010] EWCA Crim
2261, Leveson LJ identified a number of important principles relevant to sentencing such
cases:
First, punishment and deterrence are always important elements in these cases: not
only must police officers be deterred from misconduct, but also the public must see
that condign punishment will be visited on police officers who betray the trust reposed
in them and do not live up to the high standards of the police service.
Secondly, an incentive (usually money but it need not be) inevitably increases the seriousness of the
offence.
Third, misconduct, which encourages or permits criminals to behave in the
belief that they will be kept informed of areas to avoid in connection with their
criminal activities, or of those who might be informing on the police also increases its
gravity.
Fourth, any misconduct that impacts on police operations moves the offence into a different category of gravity.
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