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© Copyright, Criminal Cases Review Commission 2026.

Bennett, Liam

Published:

Liam Bennett was found guilty in a magistrates’ court of arson in August 2006 and pleaded guilty to two offences of criminal damage, two offences of burglary and two offences of attempted burglary. He was 17 at the time of the offences but 18 at the time of conviction.

Mr Bennett was sentenced in the Crown Court in May 2007 to an indeterminate sentence of Detention for Public Protection (DPP) in a Young Offender Institution under the Criminal Justice Act 2003. He was given a minimum term of two years and 82 days’ imprisonment.

Two years later Mr Bennett unsuccessfully appealed his sentence to the Court of Appeal. The Court stated that the record should be amended to reflect that Mr Bennett was in fact sentenced to Imprisonment for Public Protection (IPP) as he was aged 18 at the date of conviction.

Mr Bennett remained subject to that sentence at the time of the CCRC’s referral.

He applied to the CCRC for a review of his sentence in December 2024. Following a review it was decided that there was a real possibility that the Crown Court, properly applying the statutory test and the guidance as developed in recent caselaw, would not sentence him to IPP and would amend his sentence.

The referral arose from work done by the CCRC to examine the possible implications for other IPP/DPP cases arising from the Court of Appeal decisions in the cases of Leighton Williams [2024], Darren Hilling [2024], and Steven Sillitto [2025] who were young adults when they were sentenced.

In quashing those men’s sentences, the Court concluded that the sentencing judges had failed to attach the necessary weight to the age and maturity of the offender before imposing an indeterminate sentence. In particular, maturity should reference emotional and developmental age rather than simply biological age.

Whilst the Court of Appeal had previously considered and upheld the IPP sentence imposed on Mr Bennett, that decision was reached without the benefit of the significant judicial guidance that followed in the intervening years.

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 IPP and DPP prisoners were not freed from the terms imposed on them before abolition.

The CCRC referred the sentence in April 2026.