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CCRC refers another three indeterminate sentences (IPP and DPP) to the Court of Appeal

Published:
  • 14 IPP cases referred by the Commission so far this year  
  • 200 more IPPs/DPPs under review by casework teams   

The Criminal Cases Review Commission (CCRC) has referred to the Court of Appeal the indeterminate sentences of three men sentenced between 2006 and 2008, none of whom were given minimum terms of more than three years but all of whom remain in custody today.

These referrals are part of the Commission’s thematic, ongoing work to review IPP/DPP sentences.

Richard Lloyd was convicted in May 2008 at Coventry Crown Court of sexual assault, attempted rape, affray, theft, assault by beating, common assault, ABH, and witness intimidation. He was 26 years old at the time of sentencing and received a sentence of imprisonment for public protection (IPP) and was ordered to serve a minimum period of 37 months, minus 232 days spent on remand.

Mr Lloyd was released in July 2019 and recalled in July 2020. He remains in custody and applied to the CCRC in March 2025.

Christian Chambers was convicted in June 2006 of robbery, attempted robbery and possession of an imitation firearm. He received a sentence of detention for public protection (DPP) with a minimum term of two years, minus 48 days on remand.

The robbery took place in May 2004 when Mr Chambers was 15 years old. The other offences were committed in February 2006 when he was 17 years old.

Mr Chambers remains subject to his DPP and remains in custody, having never been released. He applied to the CCRC in October 2024.

Marlon Chen, then aged 25, was convicted in September 2006 at the Central Criminal Court of possession of a firearm with intent to endanger life. He received an IPP with a minimum term of four years, minus 384 days on remand.

Mr Chen was released from custody in March 2020 but was recalled in 2022 following his arrest and conviction for further firearms offences. He remains in custody and an application was received by the CCRC in September 2025.

Reviewing these cases, the CCRC has considered the impact of recent Court of Appeal 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, two CCRC referrals were allowed and the sentences quashed, together with those in three other indeterminate sentence cases, see the indeterminate sentences of five IPP/DPP prisoners were quashed.

CCRC Chair Dame Vera Baird KC said “These referrals demonstrate the Commission’s continuing commitment to ensuring that people serving indeterminate sentences benefit from significant changes to the Court of Appeal’s approach where appropriate.

“The three men in these cases are all still in prison despite being sentenced between 2006 and 2008. The Court of Appeal has made clear that the interaction of a young age, levels of maturity, and the assessment of future dangerousness require particular consideration. Where there is a real possibility that those principles were not properly applied, the Commission will refer the case back for a fresh appeal. The CCRC is working as fast as is realistic, given its huge caseload, to refer these cases and is grateful that they seem to be listed quickly at the Court of Appeal”.

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 Editor:    

  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 received more than 1,800 applications for reviews (convictions and/or sentences) last year. Since starting work in 1997, the CCRC has referred more than 900 cases 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.