R v Kehoe [2008] EWCA Crim 819, [2008] All ER (D) 423 (Apr)
Where an offender meets the criteria of dangerousness, there is no longer any need to protect the public by passing a sentence of life imprisonment, since the public is now protected by the imposition of the sentence of imprisonment for public protection.
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).
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