Free Drink-Driving Plea in Mitigation Template

TO THE BENCH SITTING AT OXFORD MAGISTRATES' COURT

This document is submitted on behalf of the defendant, Beatrice Imogen Kingsley, born 12 September 1985, currently employed as Self-employed dispensing optician, in respect of an alleged offence of driving or attempting to drive a motor vehicle on a road with a proportion of alcohol in the breath / blood / urine exceeding the prescribed limit, contrary to section 5(1)(a) of the Road Traffic Act 1988. The prescribed limits in England and Wales are 35 micrograms of alcohol per 100 ml of breath, 80 milligrams per 100 ml of blood, and 107 milligrams per 100 ml of urine. The case is listed for hearing on 8 July 2026 under reference OXF-26-3187-BK. The defendant pleads guilty to the offence and asks the court to sentence on the basis set out below.

The defendant is to be sentenced for driving or attempting to drive a motor vehicle on a road with a proportion of alcohol in the breath / blood / urine exceeding the prescribed limit, contrary to section 5(1)(a) of the Road Traffic Act 1988. The recorded specimen and reading are set out below.

Category 3 (mid reading — breath 60-89 / blood 138-206 / urine 184-274): starting point Band C fine, range Band C fine to medium community order, disqualification 17-22 months.

The defendant is Beatrice Imogen Kingsley, born 12 September 1985, of 15 Polstead Road, Oxford OX2 6TN, currently employed as Self-employed dispensing optician.

The defendant accepts full responsibility for the offence and is sincerely remorseful. She made the very poor decision to drive a short distance home from a colleague's leaving gathering at the Lamb and Flag, Oxford, on the evening of 17 May 2026, after misjudging both how much alcohol she had consumed and how long it had been since her last drink. She co-operated fully with the officers who stopped her at 22:48 on Banbury Road, provided breath specimens without challenge, attended interview at Cowley Police Station the following morning, and surrendered her driving licence at the first hearing on 4 June 2026. She has not driven since and has reorganised her practice so that her colleague Adesuwa Okonkwo covers her domiciliary visits. She has reflected deeply on the harm she risked to other road users — the Banbury Road is a busy thoroughfare even at that hour — and is committed to never driving after consuming alcohol again.

The Sentencing Council Drink Driving Definitive Guidelines (revised 2017, in force) place the offence in one of four categories by reference to the recorded reading. Each category sets a starting point and a range, and a minimum disqualification under section 34 of the Road Traffic Offenders Act 1988. The court then moves up or down within the range by reference to aggravating and mitigating factors, and applies guilty-plea credit under the Reduction in Sentence for a Guilty Plea guideline.

(A) Reading-band position. The recorded reading of 64 ug per 100 ml of breath places the offence in Sentencing Council Category 3 (mid reading — breath 60-89 / blood 138-206 / urine 184-274), with a starting point of a Band C fine, a range of Band C fine to medium community order, and a disqualification of 17 to 22 months. The defendant invites the court to start at the bottom of the disqualification range (17 months) given that her reading (64 ug) sits at the lower end of the Category 3 band threshold (the band runs from 60 to 89 ug), and given the substantial personal mitigation set out below. The financial sentence is asked to be at the Band C fine level, reflecting her self-employed income (declared £42,000 net 2025/26).

(B) Personal mitigation. The defendant relies on the following mitigation. (1) Genuine remorse and early acceptance: she pleaded guilty at the first hearing on 4 June 2026 and has co-operated throughout. (2) Previous good character: she holds a full clean licence since 2003 (no convictions, no endorsements, no FPNs, no NDORS attendance), confirmed by a fresh DVLA check enclosed. (3) Professional and family impact: she is a self-employed dispensing optician whose practice covers eight Oxfordshire care homes for domiciliary fittings; a longer disqualification will require her to engage and pay a locum, materially reducing income for her household (including a 14-year-old son in private school education). (4) Rehabilitative steps: she has attended four sessions of Drinkline counselling since 18 May 2026 (letter from counsellor enclosed) and has stopped consuming alcohol entirely. (5) The offence is wholly out of character; she has co-operated with police; she has not driven since the offence date despite the impact on her work.

(C) Character references. Character references are enclosed from: (i) Adesuwa Okonkwo (FBDO, fellow optician, who currently covers the defendant's domiciliary list) — addressing professionalism, reliability and conduct; (ii) Dr Linus Edmund Marchbanks (GP at Banbury Road Practice, the defendant's GP since 2014) — addressing health, alcohol-use history and the impact of the offence on the defendant; (iii) the Rev Eseosa Adekunle (St Margaret's Church, Oxford, parish minister) — addressing community involvement, the defendant's remorse and her steps since the offence. Each reference is signed, dated, and addressed to the bench.

(D) Guilty-plea credit. The defendant entered a guilty plea at the first reasonable opportunity, at the first hearing, and asks the court to apply the full one-third credit under the Sentencing Council Reduction in Sentence for a Guilty Plea guideline.

At sentencing for a drink-drive offence carrying disqualification of 12 months or more, the court may offer the defendant a place on a Drink-Drive Rehabilitation Course (DDRC) under the Drink-Drive Rehabilitation Scheme. Completion of the course reduces the disqualification by up to 25 per cent, with a minimum reduction of three months. The course costs in the region of £150 to £250, lasts about 16 hours, and must be completed within the period specified by the court (typically by a date no later than two months before the end of the disqualification).

(A) Eligibility position. The defendant is eligible for the DDRC offer: (i) the offence under s.5(1)(a) of the Road Traffic Act 1988 carries obligatory disqualification of 12 months or more (here, 17 months on the bottom of the Category 3 range); (ii) the defendant has not been disqualified from driving in the preceding 10 years (confirmed by the enclosed DVLA licence check); and (iii) she wishes to complete a course. She asks the court to make the DDRC offer at the sentencing hearing on 8 July 2026.

(B) Course completion commitment. The defendant undertakes to enrol on a course with an approved provider (the TTC Group, Oxford venue — provisional booking confirmed for 22-23 July 2026) within four weeks of sentence, to attend every session sober and on time, to engage actively with the course material, and to complete the course in good time. The course completion certificate will be lodged with the court office on or before 1 September 2026 — well within the two-month-before-end-of-disqualification cut-off.

(C) 25% reduction application. On completion the defendant asks the court to apply the standard 25 per cent reduction (a minimum reduction of three months) to the disqualification imposed. If the court imposes the 17-month disqualification asked for at the bottom of the Category 3 range, the 25 per cent reduction (4.25 months, rounded down to 4) would reduce the disqualification to 13 months, returning the defendant to the road by 8 August 2027. The defendant respectfully invites the court to specify the reduced end date at the sentencing hearing for the avoidance of doubt.

The defendant respectfully invites the court to sentence on the basis set out above, to apply the appropriate guilty-plea credit, and (where Expert sections C-E apply) to find special reasons / accept the defence version on disputed sentencing facts / offer the DDRC place. The defendant attends court ready to answer any further question the bench has.

RESPECTFULLY SUBMITTED,