Ratio Decidendi
The detention of a prisoner beyond their tariff period is only justified under Article 5(1)(a) ECHR if there remains a causal connection between the original conviction and the continued detention. The state must provide reasonable opportunities for rehabilitation.
Facts
Prisoners serving IPP sentences had passed their tariff dates but were not released because they had not been given access to courses needed to reduce their risk. They challenged the lawfulness of their continued detention.
Judgment Summary
The House of Lords held that whilst Article 5 was not breached on the facts, the state was under a duty to make reasonable provision for IPP prisoners to have the opportunity to demonstrate they were safe for release.
Key Quotes
"The state is under a duty to provide prisoners with a reasonable opportunity to rehabilitate themselves."
— Lord Brown
Subsequent Treatment
Led to further litigation on IPP prisoner rights and eventually the abolition of the IPP sentence.