Kirk Bishop, 40, pictured, started his prison term in mid-May. He had admitted seven counts of trespass, one of burglary, and nine voyeurism offences. Judge Russell Finch said they were ‘wicked and depraved offences which left lasting consequences on those affected’.
But in the Guernsey Court of Appeal Dame Julia Macur has found against Judge Finch’s approach to sentencing after she agreed that Bishop had not been given enough credit for his guilty pleas, and being prepared to reveal the pin code to his mobile phone, which allowed police to see the videos he had made.
Bishop’s advocate, Samuel Steel, also argued that the sentence was disproportionate compared to guidelines of taking indecent images of children.
After Bishop was arrested in September 2025, having been disturbed in a ground floor flat by its occupants, police found 121 voyeuristic images and videos of local people engaged in sexual activity which had been filmed on his mobile phone.
The Royal Court described the facts as ‘distinctly unusual and also distinctly unpleasant’. They were the first offences of their type seen since the 2020 sexual offences law had come into effect.
The court gave credit for guilty pleas but limited it to 25% rather than a one-third discount, because Bishop ‘plainly had no choice’. It reduced the starting point for sentencing from eight to six years’ imprisonment. English guidelines for similar offences gave a six-year starting point.
Dame Julia agreed that there were several aggravating features in the case, including the number of different victims spied upon in their own homes, the repetition of offences against some of the victims, the time period over which these offences took place, and the recording of images.
‘The harm caused in each case was significant. A starting point of eight years’ immediate imprisonment in respect of all the indictable offences is not arguably “disproportionate” and may be regarded by some as merciful,’ she said.
The court’s sentencing remarks were not clear about what reduction was attributable to the available mitigation and what for the guilty pleas, she added.
In granting the appeal, Dame Julia said: ‘That the applicant did not share the recordings is really a non-aggravating factor rather than mitigation, but it is arguable that the assistance to the prosecution, that is the voluntary provision of the pass code, did warrant some small reduction in what had been selected as the starting point of eight years, prior to giving an appropriate discount for plea.
‘It is arguable that in a case such as this in “a small jurisdiction”, the fact that the victims had been saved from giving embarrassing evidence in public was deserving of considerable weight and, regardless of the “plethora of evidence”, the discount should be one third.’
Bishop should now see his case return to the Royal Court for a new sentence to be decided.