CCRC refers two more IPP cases

The Criminal Cases Review Commission (CCRC) has made headlines by referring the indeterminate sentences of two men to the Court of Appeal, marking the 10th and 11th such cases this year. These referrals are part of a larger thematic investigation into Indeterminate Sentences for Public Protection (IPPs) and Detention for Public Protection (DPPs), with 180 more cases currently under review. These sentences were originally handed down two decades ago, with one of the individuals still in custody.

Dean Mullins, convicted of attempted murder in 2006, received an IPP with a minimum term of four years and six months. Despite his attempts to appeal in 2007, he remained subject to the IPP until his recent release on licence in April. His case exemplifies the CCRC's concern that the sentencing judges may not have given adequate consideration to his age and immaturity at the time of the offence.

Similarly, Sheldon Coore pleaded guilty to robbery in 2005 and received an IPP sentence with a minimum tariff of two years and six months. Coore's attempts to appeal did not succeed, and he is still incarcerated. The CCRC is reassessing these cases in light of recent Court of Appeal judgments, such as R v Williams [2024] EWCA Crim 686 and R v Davis & Others [2026] EWCA Crim 743, which suggest previous judges may have not fully considered the age or maturity of the defendants when evaluating their dangerousness and future risk.

The CCRC's Chair, Dame Vera Baird KC, commented on the situation, stating, “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.”

Dame Vera emphasised the potential for further referrals, remarking, “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 sentences were designed for serious offenders deemed dangerous, while DPP sentences were imposed on those under 18. Both were abolished in 2012, but existing prisoners remain bound by the sentences imposed on them prior to this change. The CCRC’s ongoing review efforts highlight a critically important reevaluation of these indeterminate sentences in the wake of evolving legal standards and perceptions regarding justice and rehabilitation.