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© Copyright, Criminal Cases Review Commission 2026.

CCRC refers nine more indeterminate sentence (IPP and DPP) cases to the Court of Appeal 

Published:
  • 25 IPP/ DPP cases referred by the Criminal Cases Review Commission so far this year  
  • More than 250 IPPs/DPPs under review by casework teams    
  • CCRC Chair Dame Vera Baird KC says public protection must remain paramount but so too must fairness 

The Criminal Cases Review Commission (CCRC) has referred to the Court of Appeal the indeterminate sentences of nine people convicted between 2005 and 2011, all but one of whom remain in custody despite none being given a minimum tariff over six years. 

The cases being referred are: 

  • Abdiwali Hassan, convicted at Isleworth Crown Court in 2011 and sentenced aged 19 to an IPP with a tariff of three years 
  • Carl Lamb, convicted at Cardiff Crown Court in 2006 and sentenced aged 26 to an IPP with a tariff of 21 months 
  • Ben Nye, convicted at Leeds Crown Court in 2007 and sentenced aged 21 to an IPP with a tariff of three years 
  • Scott Prince, convicted at Derby Crown Court in 2008 and sentenced aged 19 to an IPP with a tariff of three years and six months 
  • Liam Osborne, convicted at Wolverhampton Crown Court in 2006 and sentenced aged 21 to an IPP with a tariff of two years and three months 
  • Jerome Barrett, convicted at York Crown Court in 2005 and sentenced aged 15 to a DPP with a tariff of two years 
  • Victoria Hathaway, convicted at Ipswich Crown Court in 2009 and sentenced aged 19 to a DYPP with a tariff of six years (varied on appeal to four years) 
  • Shaun Lloyd, convicted at Cardiff Crown Court in 2005 and sentenced aged 18 to a DYPP with a tariff of two years and nine months 
  • Jason Ritchie, convicted at Teeside Crown Court in 2008 and sentenced aged 38 to an IPP with a tariff of three years 

Other than Mr Ritchie, who is on license, every applicant remains subject to their sentence in custody. For further details of each case, please see the Notes to Editors.  

These referrals are part of the Commission’s thematic, ongoing work to review IPP/DPP sentences and bring the total number of IPP/DPP cases referred since the start of the year to 25. 

In Mr Ritchie’s case, the CCRC considers there to be a real possibility the Court of Appeal will find that the judge made an error in the assessment of Mr Ritchie’s dangerousness and the failure to consider an extended determinate sentence rather than an IPP. 

Reviewing the other 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 nine referrals bring to 25 the number of IPP and DPP cases that the CCRC has referred to the Court of Appeal so far this year. 

“But while 25 referrals are a significant number, this represents only a fraction of the people who remain caught up in this abolished sentencing regime. 

“The latest figures show that 856 people who were given IPP sentences have never been released from prison. Around eight in ten of those who have passed their minimum tariff have already spent at least ten years beyond the point at which the Court originally said they should become eligible to seek release. A further 1,415 people are in custody following recall.  

“These are extraordinary figures for sentences which were abolished more than a decade ago. 

“IPP and DPP sentences were intended to protect the public by allowing someone considered dangerous to be detained beyond the minimum period set by the Court, but for many people, the result has been an indeterminate period of imprisonment that has extended far beyond that minimum term.  

“The recent judgments of the Court of Appeal have opened an important avenue for people whose sentences may have been imposed without sufficient consideration being given to their age and maturity and the assessment of future risk. Our task is to identify cases where those developments in the law may make a difference.  

“The Commission will continue to examine these cases carefully and independently. Where we identify a real possibility that a sentence would now not be upheld, we will refer the case to the appropriate court. It will then be for the Court to decide what should happen. 

“There is no simple solution to the legacy of IPP and DPP sentences. Public protection must remain paramount, but so too must fairness and the principle that people should not remain imprisoned indefinitely because of a sentencing regime that has already caused so much damage and which Parliament abolished more than a decade ago. 

“The Government may well consider it necessary for wholesale action by bringing in new legislation. We will be happy to support the Government in any way we can from the expertise our specialist team has now built up, if there is to be a plan for a quicker or wider approach. 

“In the meantime, our message to people who believe their case may be affected by these developments remains the same: if you have already appealed your sentence and lost but believe there are grounds for the CCRC to consider your case, apply to us.” 

 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. 
  1. Abdiwali Hassan was convicted at Isleworth Crown Court in January 2011 of rape and possession of an offensive weapon. He received an IPP with a minimum tariff of 3 years, less time spent on remand. He was 19 at the time of sentencing. He remains subject to that sentence in custody. He did not appeal and applied to the CCRC in December 2025.  
  1. Carl Lamb was convicted at Cardiff Crown Court in November 2006 of wounding with intent, damaging property, failure to answer bail, and breach of conditional discharge. He received an IPP with a minimum tariff of 21 months. He was 26 at the time of sentencing. He remains subject to that sentence in custody. The Single Judge refused leave to appeal in June 2007, and he applied to the CCRC in January 2026.  
  1. Ben Nye was convicted at Leeds Crown Court in May 2007 of wounding with intent to cause grievous bodily harm. He received an IPP with a minimum tariff of 3 years. He was 21 at the time of sentencing. He remains subject to that sentence in custody. Although Mr Nye indicated in his application that he applied for leave to appeal his sentence, the CCRC has been unable to find a record of either a Single Judge decision or a notice of ineffective grounds. He applied to the CCRC in August 2025.   
  1. Scott Prince was convicted at Derby Crown Court in March 2008 of wounding with intent to commit grievous bodily harm. He received an IPP with a minimum tariff of three 3 and 6 months, less 216 days on remand. He was 19 at the time of sentencing. He remains subject to that sentence in custody. The Single Judge refused leave to appeal in August 2008, and he applied to the CCRC in December 2025.  
  1. Liam Osborne was convicted at Wolverhampton Crown Court in October 2006 of arson being reckless as to whether life was endangered. He received an IPP with a tariff of 2 years and 3 months, less 72 days spent on remand. He was 21 at the time of sentencing. He remains subject to that sentence in custody. The Single Judge refused leave to appeal in February 2008, and he applied to the CCRC in November 2025.  
  1. Jerome Barrett was convicted at York Crown Court in August 2005 of robbery. He received a DPP with a minimum tariff of 2 years, less time spent on remand. He was 15 at the time of sentencing. He remains subject to the sentence in custody. Leave to appeal was refused by the Single Judge in January 2011, and he applied to the CCRC in October 2025.  
  1. Victoria Hathaway was convicted at Ipswich Crown Court in May 2009 of rape of a male child under 13, causing or inciting a child under 13 to engage in sexual activity, sexual activity with a child, and possession of indecent photographs of a child. She received a sentence of Detention for Public Protection in a Young Offenders Institution (DYPP) with a minimum tariff of 6 years, less 215 days on remand.  She was 19 at the time of sentencing. Leave to appeal the length of the notional determinate term was granted by the Single Judge in February 2010. On 31 March 2010, the Full Court considered the length of the notional determinate term and reduced it from 12 years to 8.  This reduced the minimum term of the DYPP to 4 years, less 215 days spent on remand. Ms Hathaway applied unsuccessfully to the CCRC in November 2012, April 2013 and June 2018. This application was received in June 2025.  
  1. Shaun Lloyd was convicted at Cardiff Crown Court in December 2005 of robbery and received a DYPP with a minimum term of 33 months. He was 18 at the time of sentencing. Mr Lloyd remains subject to that sentence in custody after being recalled. Leave to appeal was refused by the Single Judge in February 2014 and the Full Court in June 2014. He applied to the CCRC in January 2026. 
  1. Jason Ritchie was convicted at Teeside Crown Court in June and September 2008 of conspiracy to commit arson and putting a person in fear of violence by harassment. He received an IPP with a minimum tariff of 3 years, less 206 days on remand. At the time of sentencing, he was 38 years old. He remains subject to that sentence and is on license. Leave to appeal was refused by the single judge in February 2009. He applied to the CCRC in October 2025.