Court of Appeal, Criminal Division

Published April 28, 2008

Regina v Kehoe

Sentences of life imprisonment under section 225 of the Criminal Justice Act 2003 should be reserved for cases where the culpability of the offender was particularly high or the offence particularly grave.

The Court of Appeal, Criminal Division (Lord Phillips of Worth Matravers, Lord Chief Justice, Mr Justice Wilkie and Mr Justice Openshaw) so held in Newcastle upon Tyne, on April 8, 2008, allowing in part an appeal by Bridie Kehoe against a life sentence, with a 4½year minimum, imposed by Judge Beaumont, QC, under section 225, at the Central Criminal Court on December 4, 2007, following her guilty plea to manslaughter.

MR JUSTICE OPENSHAW said that when an offender met the criteria of dangerousness in section 225 there was no longer any need to protect the public by passing a life sentence as the public could now properly be protected by a sentence of imprisonment for public protection.

Cases decided before the 2003 Act came into effect no longer offered guidance on when a life sentence should be imposed.

The life sentence would be quashed and a sentence of imprisonment for public protection with a three-year minimum term would be substituted.

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