Background
Hao Feng pleaded guilty to the manslaughter of his partner, Wang Xiaoyang, after an amended charge was accepted shortly before his scheduled murder trial. During an argument at Ms Wang’s home on 10 January 2025, Feng put at least one hand around her neck until she lost consciousness and fell. He moved her to a couch, later found that she had died, and the cause of death was manual strangulation.
Feng arranged care for his 12-year-old daughter, told a friend he thought he had killed his girlfriend, and drove to a police station early the next morning. He then directed police to Ms Wang’s body. The Court sentenced on the agreed facts, rather than Feng’s account that Ms Wang had been assaulting him, as he did not advance self-defence or provocation.
The Court’s Holding
Walker J imposed four years and two months’ imprisonment. The Court set a seven-year starting point, reflecting the lethal strangulation of an intimate partner in her own home, the vulnerability of the neck, the breach of trust in the relationship, the widespread impact of Ms Wang’s death, and Feng’s failure to seek medical help before leaving to smoke.
The Court found no premeditation, protection-order breach, or evidence of other physical injuries. It regarded R v Curran as the closest comparable authority but more serious because it involved ligature strangulation, other violence, and post-offence concealment. The Court reduced the sentence by 40 per cent: 20 per cent for the guilty plea, five per cent for the added hardship of imprisonment as a non-English-speaking foreign national, five per cent for remorse, and 10 per cent for Feng’s otherwise blame-free life, background, personal circumstances, and the effect on his daughters.
Key Takeaways
- Manual strangulation causing death justified a seven-year starting point for manslaughter in these circumstances.
- Failure to seek medical assistance was aggravating, although Feng’s prompt surrender and cooperation were recognised.
- A late plea still attracted 20 per cent credit because disclosure and translation needs reasonably delayed negotiations on the amended charge.
Why It Matters
The decision illustrates the High Court’s approach to sentencing intimate-partner manslaughter by strangulation where murderous intent cannot be proved. It treats the inherent danger and terror of neck compression, and the victim’s vulnerability within her home and relationship, as central sentencing considerations.
It also shows that sentencing remains fact-specific: comparable strangulation cases assist, but differences in force, duration, additional violence, and post-offence conduct materially affect the starting point and ultimate sentence.