Sentence – Life imprisonment. The appeal concerned whether, where the defendant had pleaded guilty to manslaughter for an offence committed in 2000 and had been sentenced to a discretionary life sentence 14 years later in 2014, art 7(1) of the European Convention on Human Rights operated to prevent the court imposing on the defendant a longer minimum term than would have been imposed on him at the time of the commission of the offence. The Court of Appeal, Criminal Division, in dismissing the defendant's appeal against the specified minimum term, held that the recorder's reasoning had been entirely sound. He had rightly distinguished R v Sullivan ([2004] All ER (D) 133 (Jul)) and had followed the principles in R v H ([2011] EWCA Crim 2753).