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

Seven more indeterminate sentences for public protection (IPP and DPP) cases referred to the Court of Appeal by the CCRC

Published:
  • 32 IPP/ DPP cases have been referred by the Criminal Cases Review Commission so far this year  
  • More than 250 IPPs/DPPs are currently under review by CCRC casework teams  
  • CCRC Chair Dame Vera Baird KC says ‘this work remains a significant priority for the Commission’  

The Criminal Cases Review Commission (CCRC) has referred to the Court of Appeal the indeterminate sentences of seven people convicted between 2005 and 2012, all of whom remain in custody despite none being given a minimum tariff over seven and a half years. 

The cases being referred are: 

  • Michael Seddon, convicted of robbery at Bournemouth Crown Court in 2011 and sentenced aged 23 to an IPP with a tariff of seven and a half years. 
  • Andre Hurst, convicted of aggravated burglary and grievous bodily harm in 2008 and sentenced aged 20 to a DPP (which should have been an IPP) with a tariff of four years. 
  • Gemma Smith, convicted of robbery at Southampton Crown Court in 2005 and sentenced aged 19 to a DPP (which should have been an IPP) with a tariff of 22 and a half months. 
  • Scott Hulme, convicted of causing grievous bodily harm with intent at Chester Crown Court in 2009 and sentenced aged 18 to a DPP with a tariff of one year and 243 days. 
  • Joshua Gordon, convicted of aggravated burglary at Lewes Crown Court in 2009 and sentenced aged 23 to an IPP with a tariff of four years. 
  • David Hill, convicted of robbery at Kingston-Upon-Hull Crown Court in 2011 and sentenced aged 21 to an IPP with a tariff of four and a half years. 
  • Ryan Helstern, convicted of robbery at Peterborough Crown Court in 2012 and sentenced aged 17 to a DPP with a tariff of 27 months. 

Despite all being considerably over tariff, every applicant remains subject to their sentence in custody. For further details of each case, please see the Notes to Editors.  

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. 

These referrals are part of the Commission’s thematic, ongoing work to review those cases with IPP/DPP sentences which have been the subject of an application to the Commission. They bring the total number of IPP/DPP cases referred since the start of the year to 32. 

Reviewing the 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 see  the indeterminate sentences of five IPP/DPP prisoners were quashed. and has concluded that in each of these current cases there is a real possibility the Court find, similarly, that the sentencing judges may not have given sufficient weight to the age and immaturity of the applicant when assessing their dangerousness and future risk.   

CCRC Chair Dame Vera Baird KC said: “The Commission remains committed to identifying IPP and DPP cases where developments in the law suggest that an indeterminate sentence may have been wrongly imposed.  

“These seven applicants were all young when sentenced; all received relatively short tariffs, yet all remain in custody long after those tariffs expired. Considering recent Court of Appeal decisions, we believe there is a real possibility that insufficient weight was given to their youth and immaturity when their dangerousness was assessed. 

“With more than 250 IPP and DPP cases currently under review, this work remains a significant priority for the Commission. 

“This month I met with UNGRIPP, a support group for the families of people still serving IPP sentences, in the House of Commons. Each person had a relative on an IPP, some having been released but recalled, some currently adjusting to life outside of prison with support, and some who have never been released from prison.” 

[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, because 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. Michael Seddon was convicted at Bournemouth Crown Court in November 2011 of robbery. He received an IPP with a tariff of 7 years and 6 months, less 9 days on remand. At the time of sentencing, he was 23. He remains subject to that sentence in custody. Leave to appeal was refused by the Single Judge in November 2011 and the Full Court in July 2012. He applied to the CCRC in April 2026. 
  1. Andre Hurst was convicted as Andre Parker at Oxford Crown Court in June 2008 of aggravated burglary and grievous bodily harm. He received a DPP with a tariff of four years. At the time of sentencing, he was 20. Due to his age, he should have been sentenced to an IPP but this has never been formally corrected. He remains subject to that sentence in custody. Leave to appeal against sentence was refused by the Single Judge in January 2017 and the Full Court in November 2023. He applied to the CCRC in October 2025. 
  1. Gemma Smith, tried and appealed as Ian Woolnough, was convicted at Southampton Crown Court in October 2005 of robbery. She received a DPP with a tariff of 22 and a half months, less 70 days on remand. At the time of sentencing, she was 19. She remains subject to that sentence in custody. She should have been sentenced to an IPP however this has not been formally corrected. Leave to appeal against sentence was granted by the Single Judge in February 2006, but the sentence was upheld. She applied to the CCRC in September 2025. 
  1. Scott Hulme was convicted at Chester Crown Court in August 2009 of causing grievous bodily harm with intent. He received a DPP with a tariff of one year and 243 days. At the time of sentencing, he was 18. He remains subject to that sentence in custody following recall. Mr Hulme has not appealed against conviction or sentence. He applied to the CCRC in December 2025. 
  1. Joshua Gordon was convicted at Lewes Crown Court in November 2009 of aggravated burglary. He received an IPP with a tariff of 4 years. At the time of sentencing, he was 23. He remains subject to that sentence in custody. Leave to appeal was refused by the Single Judge in May 2010 and the Full Court in July 2010. He applied to the CCRC in May 2025.  
  1. David Hill was convicted at Kingston-Upon-Hull Crown Court in January 2011 of robbery. He received an IPP with a tariff of four years and 6 months. At the time of sentencing, he was 21. He remains subject to that sentence in custody. An appeal against sentence was refused by the Full Court in January 2012. He applied to the CCRC in May 2025.  
  1. Ryan Helstern was convicted at Peterborough Crown Court in March 2012 of robbery. He received a DPP with a tariff of 27 months. At the time of sentencing, he was 17. He remains subject to that sentence in custody. The Full Court dismissed an appeal against sentence in September 2012. He applied to the CCRC in November 2025.