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CCRC refers two more Indeterminate Sentences for Public Protection (IPPs) to the Court of Appeal

Published:
  • The 10th and 11th IPP cases referred by the Commission so far this year  
  • 180 more IPPs/DPPs are under review by the Commission’s casework teams   

The Criminal Cases Review Commission (CCRC) has referred to the Court of Appeal the indeterminate sentences of two men given minimum terms of four and a half and two and a half years, two decades ago, one of whom remains in custody today.

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

Dean Mullins, who was 24 at the time of the offence, pleaded guilty to attempted murder in October 2006 at Leeds Crown Court. He received a sentence of imprisonment for public protection (IPP) with a minimum term of four years and six months, less 162 days spent on remand.

Mr Mullins tried unsuccessfully to appeal against his sentence in 2007. He applied to the CCRC in November 2025. He remains subject to his IPP sentence but was released on licence in April of this year.

Sheldon Coore pleaded guilty to robbery at Bradford Crown Court in June 2005. He received a sentence of IPP with a minimum tariff of two years and six months.

Mr Coore also tried unsuccessfully to appeal against his sentence and applied to the CCRC in August last year. He is still in custody.

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, which were not our referrals; see the indeterminate sentences of five IPP/DPP prisoners were quashed.

CCRC Chair Dame Vera Baird KC said: “Our thematic work on IPP and DPP sentences is ongoing. These sentences were handed down to children and relatively young adults long ago, before the IPP/DPP sentences were abolished by statute.

“One would wish for a whole re-sentencing exercise to check the appropriateness of all these leftover cases. Clearly, we will continue to review cases and refer to the Courts the ones where we have identified a real possibility that these indeterminate sentences will not be upheld.

“More than 180 similar cases are under investigation, and we believe many more could be referred in the coming months in light of the recent judgments of the Court of Appeal in cases where age and immaturity were not properly taken into account by sentencing judges when assessing any future risk defendants might pose to the public”.

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.