Criminal law – Burglary. The Court of Appeal, Criminal Division, held, on a reference under s 36 of the Criminal Justice Act 1988, that the offender's total sentence of two years' imprisonment for four offences, namely, two counts of causing criminal damage, one count of burglary of a dwelling and one count of assault occasioning actual bodily harm, had been unduly lenient. In the circumstances, the total term was increased to one of three years' imprisonment.