Sentence – Custodial sentence. The applicant complained, under art 5(1) of the European Convention on Human Rights, that his detention was arbitrary because the Parole Board had refused to recommend his release on the ground that he had not yet completed the extended sex offenders treatment programme, despite the fact that he had been unable to access that course. The European Court of Human Rights, in dismissing the application, held that a real opportunity for rehabilitation had been provided to the applicant and there had been no unreasonable delay in providing him access to courses. Accordingly, there had been no violation of art 5(1) of the Convention.