Skip to content
© Copyright, Criminal Cases Review Commission 2026.

IPPs and DPPs: CCRC refers five people’s indeterminate sentences for appeal

Published:

The Criminal Cases Review Commission (CCRC) has today [Tuesday 27 January] referred five people’s IPP/DPP sentences to the appellate courts after the Court of Appeal recently quashed indeterminate sentences which were imposed on other men at a similarly young age. 

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 the 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 

These five referrals arise 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.  

The sentences in all five of the cases being sent back to the courts today were imposed on relatively young men, more than 15 years ago, none with a tariff over three and a half years. In three of those, imposed almost 20 years ago, the highest tariff was a year and nine months. All five men remain in prison. 

The five sentences referred are those of: 

  • Benjamin Hibbert, who was convicted of three counts of sexual assault at Preston Crown Court in December 2009. He was sentenced to DPP with a minimum tariff of two years. He was aged 15 or 16 at the time of the offences. 
  • Stuart O’Neill was convicted of rape at Manchester Crown Court in October 2009. He was sentenced to IPP with a minimum term of three years and six months. He applied for leave to appeal his sentence, but it was dismissed by the Court of Appeal in March 2010. He was aged 20 when he was sentenced. 
  • Jay Davis was convicted of possessing a firearm with intent to cause fear or violence in Portsmouth Crown Court in October 2006. He was sentenced to IPP with a minimum term of nine-months. He was 19 at the time of the offence. 
  • Luke Ings was convicted of two counts of robbery and two counts of battery at East Berkshire Youth Court in March 2006. He was sentenced at the Crown Court to DPP with a minimum term of one year nine months minus 81 days on remand. He was 17 at the time of the offence.  
  • James Ward was convicted of arson and criminal damage in June 2006 at Leicester Magistrates’ Court and was sentenced at Leicester Crown Court. He was sentenced to one year minus 63 days on remand. He was 20 at the time of the offence. 

The cases of Mr Hibbert, Mr O’Neill and Mr Davis are being referred to the Court of Appeal, and Mr Ings’ and Mr Ward’s cases are being referred to the Crown Court. 

CCRC Chair Dame Vera Baird KC said: 

“The CCRC has set up a special project group, following the Hilling, Williams and Sillitto decisions because the principle set out there seems likely to be applicable to other people still on IPPs or DPPs.  

“For many years there has not been such a possibility for such people. So, we have set up a focussed team of case review managers and a specialist standing committee of Commissioners to ensure specialist experience and expertise in both investigation and decision-making for these cases.  

“We are currently receiving an average of 16 IPP/DPP cases a month and about 110 cases are on our stocks for review. We have also begun a search of earlier IPP/DPP cases which came to us but were not referred to the courts to see if the new cases might have an impact also on them.  

“I am pleased we have already been able to refer the sentences of these five people.  

“The judgments that have been made recently by the Court of Appeal provide an important opportunity to try to help other young people who were in similar circumstances at the time of their conviction and who received sentences of this kind. 

“Anyone else in a similar situation and who – importantly – has exhausted their appeal rights is free to get in touch with us.” 

[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 ten 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.