Sentence – Murder. Following the repatriation of the defendant who was serving a life sentence for murder in Germany, the Secretary of State referred his case to the court for the making of an order under s 269(2) or (4) of the Criminal Justice Act 2003. The Queen's Bench Division held that, as the evidence was that the defendant's release in Germany before serving 20 years would have been highly improbable, the appropriate minimum term was one of 20 years, less the 496 days he had spent on remand in pre-trial custody and awaiting extradition.