Brown v Parole Board for Scotland and another

Prisoner – Rehabilitation – Extended sentence. Court of Session: Refusing an appeal by a prisoner who was serving an extended sentence and who contended that he had not been given certain courses in prison which the Parole Board for Scotland had recommended and that his Convention rights had been breached, the court held that an extended sentence was a determinate sentence and the implied ancillary duty under art 5(1) of the Human Rights Convention to provide a reasonable opportunity to certain prisoners to work towards rehabilitation to facilitate release was confined to cases involving indeterminate sentences.

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