R v Kehoe [2008] EWCA Crim 819, [2008] All ER (D) 423 (Apr)
The cases decided before the Criminal Justice Act 2003 came into effect therefore no longer offer guidance on when a life sentence should be imposed. Now, “when the court finds that the defendant satisfies the criteria for dangerousness, a life sentence [under s 225 of the 2003 Act] should be reserved for those cases where the culpability of the offender is particularly high or the offence itself particularly grave” (per Mr Justice Openshaw at 17).
