SENTENCING STATEMENTS
A judge may decide to publish a statement after passing sentence on an offender in cases where there is particular public interest; where a case has legal significance; or where providing the reasons for the decision might assist public understanding.
Please note that statements may include graphic details of offences when it is necessary to fully explain the reasons behind a sentencing decision.
Follow us if you wish to receive alerts as soon as statements are published.
Once charges are spent, any statement in relation to them is removed and cannot be provided or acknowledged. Statements published before the launch of the website may be available on request. Please email judicialcomms@scotcourts.gov.uk.
The independence of the judiciary is essential to safeguard people’s rights under law - enabling judges to make decisions impartially based solely on evidence and law, without interference or influence from the government or politicians.
When deciding a sentence, a judge must deal with the offence that the offender has been convicted of, taking into account the unique circumstances of each particular case. The judge will carefully consider the facts that are presented to the Court by both the prosecution and by the defence.
For more information about how judges decide sentences; what sentences are available; and matters such as temporary release, see the independent Scottish Sentencing Council website.
Read more about victims of crime and sentencing.
HMA v Mark Keel
May 27, 2025
On sentencing, Lord Mulholland said:
“Mark Keel, you have pled guilty to murdering your partner, Maxine Clark. You brutally and savagely attacked her, a defenceless woman, to the extent that she died from the injuries you inflicted. To give you and the public a reminder of the extent of your violence, she sustained at your hands 51 separate injuries. These included a significant 60g bleed on the brain causing brain herniation, blunt force bruising and lacerations to her face and head, multiple bruises and lacerations within her mouth. Her jaw was fractured, caused by you stamping on her jaw as her head lay against the floor. Haemorrhages at the jaw and rear of the mouth and her tongue. Fractures to seven ribs with several of these ribs being fractured in more than one place. A collapsed lung. Haemorrhages on the chest wall, left breast, the areas surrounding the heart, the bowel, spleen, pancreas and colon. Her liver was lacerated. She had bruising to the pelvis and her vaginal area. You stamped on her leg leaving the imprint of the soles of both your shoes on her leg. Ultimately the injuries you inflicted caused cardiorespiratory arrest. The injuries were caused by multiple blows such as punches and kicks and stamps. The force used by you to inflict these injuries was such that impact spatter blood spots were recovered on the headboard of the bed.
Not content with causing this catalogue of injuries, and whilst she lay dying, you did not get medical help for her. To the contrary, you pretended that she had suffered an allergic reaction and there was no need to call an ambulance. When G4S staff attended at your home address to fit a tag on your leg, you told them to come back later. When you eventually called an ambulance, you told them that she had a swollen tongue and was struggling to breath. This call was the best part of at least half a day after you had savagely beaten her. What you did to this defenceless woman was cowardly and evil. They were the actions of a brute.
You have a history of domestic violence as confirmed by your criminal record and in the agreed narrative read to the court. You have been violent to three previous partners, and you were also violent to Maxine Clark. Witnesses speak to seeing her with black eyes and grab marks to her neck.
I also note that at the time of the murder you were subject to a community payback order with a curfew and a restriction of liberty order for a previous domestic abuse conviction.
In imposing sentence, I take into account all the circumstances including the seriousness of your crime, the extent and nature of the violence, your criminal history, your record of domestic violence, the Victim Impact Statements which detail the effect of your crime on the parents of the deceased, she was their only child, which are heartbreaking in their terms, the terms of the Criminal Justice Social Work Report, everything that has been said on your behalf and in respect of the punishment part the timing of your plea of guilty and the benefits that brings to the criminal justice system as a whole.
I will now sentence you for the murder of Maxine Clark. There is only one sentence prescribed by law and that is life imprisonment which is the sentence which I impose. The sentence will run from 1 July 2024, which is the date you were first ordered into custody by the court for this matter.
I am also required by law to impose a punishment part. The punishment part is the period of time you will serve in prison before you can apply for parole. I say apply, as there is no guarantee that you will ever be granted parole and you may never be released from prison. You are assessed as posing a very high risk to women in a relationship with you. You will only be released if you are considered by the parole board to pose no risk to the public, particularly women, and that is a long way off, if ever. That is a decision for the parole board alone to take.
In fixing the punishment part, I must reflect the need to punish you for the crime of murder and to deter you and others from committing murder. The law requires me to ignore any risk that you may pose to the public in the future.
Had you not pled guilty when you did, I would have imposed a punishment part of 24 years’ imprisonment. Taking account of the timing of your plea of guilty, I will fix the punishment part at 22 years’ imprisonment. I apportion two years for the partner aggravation in terms of Section 1 of the Abusive Behaviour and Sexual Harm (Scotland) Act 2016.”