R v Knights (Secretary of State for Justice intervening)

Sentence – Custodial sentence. Sixteen days after the defendant was sentenced to Indefinite Imprisonment for Public Protection (IPP), the law was amended in that, had he been sentenced after the change in law, a sentence of IPP would not have been open to the judge on the facts of the present case. The Court of Appeal, Criminal Division, in dismissing a reference by the Criminal Cases Review Commission to appeal against the defendant's sentence, held that, he should not have the benefit of the amendments as the court was bound by the decision of the Supreme Court in R v Docherty ([2016] All ER (D) 72 (Dec)).

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