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© Copyright, Criminal Cases Review Commission 2026.

CCRC refers cases of two men, given IPP sentences, who are still in prison nearly 20 years after minimum terms ended

Published:
  • The CCRC has referred nine IPP/DPP cases during 2026
  • We are working on more than 180 other IPP/ DPP cases

The Criminal Cases Review Commission (CCRC) has referred to the Court of Appeal the indeterminate sentences of two men given 18-month and 24-month minimum jail terms in 2005 and 2006, but who are still in custody.

This is part of the Commission’s ongoing thematic work to review IPP/DPP sentences.

Christopher Brown, who was 18 at the time of the offence, was convicted in November 2005 at Exeter Crown Court of arson after setting fire to two wheelie bins. He received a sentence of Imprisonment for Public Protection (IPP) with a minimum term of 18 months.

Jamie Jackson, who was 19 at the time of the offence, was convicted in July 2006 at Cambridge Crown Court of wounding with intent and received a sentence of IPP with a minimum tariff of two years.

Reviewing these cases, the CCRC has considered the impact of recent court judgments, in particular R v Williams [2024] EWCA Crim 686 and R v Davis & Others [2026] EWCA Crim 743 and has concluded that in each case there is a real possibility the Court will now find that the sentencing judges did not give sufficient weight to the age and immaturity of each applicant when assessing their dangerousness and future risk.

The Court has recently overturned several similar IPP/DPP sentences. On 23 April, the indeterminate sentences of five IPP/DPP prisoners were quashed, two of them following CCRC referrals.

CCRC Chair Dame Vera Baird KC said: “The Court of Appeal’s recent considered judgment, delivered some weeks after they freed five IPP prisoners in the case of Davis & others, has endorsed the principles upon which we have based our recent IPP and DPP referrals.

“The judgment reinforced, with clarity, that age and maturity are significant factors in both assessing dangerousness and in choosing the appropriate disposal.

“There is a real possibility the Court will take the same approach in the cases of Mr Jackson and Mr Brown.”

IPP (Imprisonment for Public Protection) sentences were indeterminate sentences intended for serious offenders who were considered dangerous to the public.

DPP (Detention for Public Protection) sentences were similar indeterminate sentences imposed on people aged under 18 who were considered dangerous.

Both types of sentences were abolished in 2012, but current IPP and DPP prisoners have not been freed from the terms imposed on them before abolition.

[ENDS]

Notes to editors: 

  1. The CCRC is an independent body set up under the Criminal Appeal Act 1995. It is responsible for independently reviewing suspected and alleged miscarriages of criminal justice in England, Wales and Northern Ireland. It is based in Birmingham and is funded by the Ministry of Justice.        
  1. There are currently 16 Commissioners who bring to the CCRC considerable experience from a wide variety of backgrounds. Commissioners are appointed by the monarch on the recommendation of the Prime Minister in accordance with the Office for the Commissioner for Public Appointments’ Code of Practice.     
  1. The CCRC usually receives around 1,600 applications for reviews (convictions and/or sentences) each year. Since starting work in 1997, the CCRC has referred around 3% of applications to the appeal courts.        
  1. The CCRC considers whether, as a result of new information or a new argument on a point of law, there is a real possibility that the sentence would not be upheld were a reference to be made. New information or argument on a point of law is argument or information which has not been raised during the original sentence hearing or on appeal.  Applicants should usually have appealed first. A sentence can be referred in the absence of an earlier appeal only if there are “exceptional circumstances”.       
  1. If a case is referred, it is then for the appeal court to decide whether the sentence should be changed.          
  1. More details about the role and work of the Criminal Cases Review Commission can be found at www.ccrc.gov.uk. The CCRC can be found on X, Facebook, Instagram (@the_ccrc) and Linkedin.