Imprisonment for Public Protection as a Last Resort: The Duty to Consider Extended Sentences – Commentary on R v Zulfqar [2025] EWCA Crim 1683

1. Introduction

This commentary examines the decision of the Court of Appeal (Criminal Division) in R v Zulfqar [2025] EWCA Crim 1683, a case which revisits the now‑abolished regime of Imprisonment for Public Protection (IPP) and clarifies the sentencing court’s duty, even under the pre‑LASPO dangerous offender provisions, to:

• treat IPP as a sentence of last resort; and
• expressly consider and explain why an extended sentence (ES) and other protective measures would not provide sufficient public protection.

The applicant, Mohammed Zulfqar, was sentenced in 2010 to IPP with a minimum term of three years (less time on remand) for a serious attempted stranger rape. No appeal was brought at the time. He remained in custody for many years, was only released by the Parole Board in 2025, and then sought, very late, to challenge the lawfulness of the IPP sentence.

The Court of Appeal granted a very substantial extension of time, allowed the appeal, quashed the IPP, and substituted an extended sentence. In doing so, the court reaffirmed and sharpened the guidance given in Attorney General’s Reference No 55 of 2008 (R v C and others) [2008] EWCA Crim 2790, [2009] 1 WLR 2158, and clarified the limited relevance of R v Howlett [2019] EWCA Crim 1224 in this particular context.

The judgment also contains practical guidance on late appeals against historic IPP sentences and on what must appear in sentencing remarks when a judge opts for IPP rather than an extended sentence.

2. Summary of the Judgment

2.1 Facts in brief

In October 2009 the applicant, then aged 22, attempted to rape a 24‑year‑old woman who was walking alone at night following an argument with her husband (para 6). Key features included:

• He followed and targeted her as a stranger in the street.
• He pushed her into a bus shelter, pinned her, tried to persuade her to come to his flat for sex.
• He kissed and groped her, pressed his groin against hers, grabbed her hair and wrists.
• He pushed her into bushes down a small hill, got on top of her, and threatened to kill her.
• He threatened to use a knife (the victim felt something being poked into her).
• He pulled up her top and tried to pull down her jeans; the judge had “no doubt” rape would have followed but for intervention by two passing brothers.

The psychological impact on the victim was profound and enduring: loss of independence, sharp restriction of her movements, sleep disturbance, hyper‑vigilance, and strain on her marriage and family life (para 7).

The applicant had a significant criminal history, including robbery, burglary, weapon possession, dangerous driving and drink‑driving. He was on licence at the time of the offence (para 8).

2.2 Procedural history

• February 2010: At Birmingham Crown Court, after a guilty plea, His Honour Judge Faber found the applicant to be “dangerous” and imposed IPP with a minimum term of three years less one day in custody (para 2).
• The applicant was placed on the sex offenders’ register for life and made subject to indefinite notification requirements (para 2).
• No appeal was lodged at the time (para 3).
• He remained in custody for many years, and in July 2025 the Parole Board directed his release on life licence (para 3).
• In 2024–2025, new legal representatives identified potential grounds challenging the lawfulness of the IPP sentence itself, leading to a renewed application for leave to appeal well out of time — more than 14 years late (paras 4, 16–17).

2.3 The Court of Appeal’s decision

The Court of Appeal (Cheema‑Grubb J giving the judgment):

• Granted the necessary extensions of time and leave to appeal “to avoid injustice” (para 32).
• Held that the sentencing judge had erred in principle by:
  • failing to follow the approach mandated in Attorney General’s Reference No 55 of 2008;
  • failing to expressly consider an extended sentence as an alternative to IPP; and
  • failing to give any reasons why an extended sentence would not adequately protect the public (paras 26–28, 31–32).
• Concluded that nothing in the facts or in the pre‑sentence report justified the conclusion that only IPP could protect the public; an extended sentence would have sufficed (paras 27, 33).
• Quashed the IPP sentence and substituted an extended sentence comprising:
  • a custodial term of six years less one day; and
  • an extension period of five years (para 34).
  Both were ordered to take effect from the date of the original sentence.
• Confirmed that the applicant remains subject to life‑long registration under the sex offenders’ register (para 34).

The core legal message is that, where IPP is discretionary, failure to demonstrate in the sentencing remarks proper consideration of an extended sentence and other protective measures will be treated as a material error in principle, warranting appellate intervention even many years later.

3. Legal Framework at the Time of Sentencing

3.1 The dangerous offender regime (pre‑LASPO)

The applicant was sentenced in 2010 under the dangerous offender provisions of the Criminal Justice Act 2003 (“CJA 2003”), as amended with effect from July 2008. In very broad terms:

• The court had to decide whether the offender was “dangerous” — that is, whether he posed a significant risk of serious harm to members of the public from future commission of specified offences.
• If dangerousness was found and a life sentence was not mandatory, the court had a discretion to choose between:
  • Imprisonment for Public Protection (IPP); or
  • a discretionary extended sentence (ES).

The judgment refers to section 227 CJA 2003 as the relevant provision for both IPP and extended sentences (para 23–24). Strictly, under the original CJA 2003 scheme:

• Section 225 governed IPP; and
• Section 227 governed extended sentences.

However, the Court’s summary (paras 23–24) accurately captures the key functional features of the regime:

• After the July 2008 amendments, IPP was no longer mandatory when criteria were met; the court “may” impose IPP if either:
  • the offender had a previous conviction for a “relevant offence”; or
  • the notional minimum term to be specified for IPP would be at least two years (para 23).
• Alternatively, where the offender was dangerous and:
  • had a previous conviction for a relevant offence; or
  • the appropriate custodial term would be at least four years,
  the court could impose an extended sentence: a custodial term plus an “extension period” on licence for such further period as necessary for public protection (para 24).
• For specified sexual offences, as here, the maximum extension period was eight years (para 24).

In short, by 2010 the court had a genuine choice between IPP and ES. That choice had to be made by reference to the level of risk and the most proportionate way to protect the public.

3.2 Guideline for (attempted) rape

The parties agreed that under the (then) Sentencing Guidelines Council guideline for rape of an adult, this case — despite being an attempted rape — attracted:

• a starting point of eight years’ custody for a first‑time offender after trial; and
• a range of six to eleven years (para 10).

This was because the offending was:

• sustained;
• involved threats to use a knife and to kill; and
• only interrupted by brave third‑party intervention (paras 6, 13).

The sentencing judge expressly recognised that some attempted rapes can be more serious than some completed rapes and regarded this case as falling into that category (para 13).

3.3 Appeal and extension of time

Under the Criminal Appeal Act 1968, appeals against sentence must be brought within a strict time limit, but the Court of Appeal has a power to extend time where the interests of justice require. In this case:

• The applicant was out of time by over 14 years for an appeal against the original sentence (para 4).
• He was also 15 days late in renewing his application after the single judge’s refusal (para 4).
• The Court treated these delays as excusable in light of:
  • initial advice that there were no grounds of appeal (para 16);
  • late discovery in custody (in 2023) that there might be arguable grounds (para 16);
  • prompt action once new solicitors were instructed and transcripts obtained (para 16); and
  • prison administrative failures in notification of the single judge’s decision (para 17).
• The Court explicitly grounded the extensions in the need “to avoid injustice” (para 32).

Thus the court signalled that, especially in the context of draconian sentences such as IPP, it will be prepared to relax time limits where an arguable error in principle emerges late but continues to have serious consequences for the offender.

4. Precedents and Authorities Considered

4.1 Attorney General’s Reference (No 55 of 2008) (R v C and others)

The central authority is Attorney General’s Reference No 55 of 2008 (R v C and others) [2008] EWCA Crim 2790; [2009] 1 WLR 2158. Lord Judge CJ there laid down important principles on the use of IPP.

Three key points from C, as adopted in Zulfqar, are:

1. IPP is the most draconian sentence short of life imprisonment.
   The Chief Justice stated that “apart from the discretionary sentence of life imprisonment, imprisonment for public protection when the necessary conditions are fulfilled, is the most draconian sentence available to the court” (quoted at para 25).
2. The court must consider all alternative methods of public protection.
   At para 14 of C, Lord Judge emphasised that, even where the criteria for IPP are met:

   “…the court is entitled to and should have in mind all the alternative and cumulative methods of providing the necessary public protection against the risk posed by the individual offender. For example, structured around a determinate sentence, or indeed an extended sentence… a sexual offences prevention order, with appropriate conditions attached could form part of what we may colloquially describe as the total protective sentencing package.”

3. If that overall “sentencing package” would provide adequate protection, IPP should not be imposed.
   Lord Judge concluded:

   “If what we have described as the overall sentencing package provides appropriate protection, imprisonment for public protection should not be imposed.”

The Court of Appeal in Zulfqar holds that this approach ought to have been followed in 2010 but was not. The sentencing judge:

• did not advert to extended sentence as an option at all (para 15); and
• gave no explanation of why lesser measures would be inadequate (para 26–27).

Cheema‑Grubb J notes that this governing guidance from C was not referred to by counsel at the time (para 26), but that omission did not relieve the judge of the duty to apply it.

4.2 R v Howlett [2019] EWCA Crim 1224

The respondent relied on R v Howlett to suggest appellate courts should very rarely interfere with a trial judge’s assessment of dangerousness (paras 28–30). In Howlett:

• The defendant received an extended sentence of 22 years (18 years’ custody + 4 years’ extended licence) for extremely serious, pre‑planned violence including life‑threatening knife injuries (para 28).
• The appeal challenged both the finding of dangerousness and the length of the sentence; the Court of Appeal upheld the sentence.
• The principle drawn was that it would be “a rare case” where an appellate court which had not conducted the trial and seen the offender would overturn an assessment of dangerousness (para 30).

In Zulfqar, the Court accepts this general principle but explains why Howlett is of limited relevance:

• The applicant in Zulfqar did not challenge the dangerousness finding; his counsel “realistically accepts” that the judge was entitled to find him dangerous (para 19).
• The challenge was instead directed to:
  • the choice of disposal (IPP rather than ES); and
  • the judge’s failure to consider or explain alternatives (para 19, 31).
• Thus the appellate court was not being asked to revisit a fact‑sensitive assessment of risk, but to correct a legal error in the exercise of sentencing discretion and non‑compliance with the statutory framework as interpreted in C.

The judgment therefore clarifies that:

• Howlett governs when and how appellate courts may revisit findings of dangerousness; but
• it does not insulate a sentence from appellate scrutiny where the complaint is that the judge failed to consider the proper array of sentencing options or failed to explain why the most draconian option was chosen.

4.3 Other relevant materials

4.3.1 The pre‑sentence report (PSR)

The PSR in 2010:

• Assessed the applicant as posing a high risk of serious harm, including both violent and sexual offending (paras 9(4) and 9(6)).
• Identified alcohol misuse, emotional instability, and impulsivity as key risk factors (para 9(2)–(4)).
• Concluded that the risk could not then be safely managed in the community, recommending custody with “robust licence conditions” (para 9(5)).
• Incorrectly stated that the offence gave rise to a presumption of risk and eligibility for IPP (para 9(6)), an error recognised by all at the sentencing hearing; the judge proceeded on the basis that no such presumption applied.

The Court later notes that there was nothing in either the facts or the PSR that compelled the conclusion that only IPP could safely manage the risk; there was no analysis of why an extended sentence plus strict licence conditions would be inadequate (para 27).

4.3.2 Sexual Offences (Amendment) Act 1992

The judgment opens by reminding readers that the victim is protected by the Sexual Offences (Amendment) Act 1992 (para 1), which prohibits publications from including information likely to identify the victim of a sexual offence unless the statutory anonymity is waived or lifted. The Court scrupulously observes that requirement.

5. The Court’s Legal Reasoning

5.1 Identifying the error in principle

The critical legal flaw in the original sentence is summarised at paras 26–28 and 31–33:

• The sentencing judge:
  • found the applicant dangerous; and
  • stated that “the only appropriate sentence” was IPP (para 14).
• However, he did not:
  • refer to an extended sentence at all (para 15);
  • articulate any reasoning as to why an extended sentence could not adequately protect the public (para 15, 26); or
  • engage with the approach set out in C — namely, that IPP is a last resort, to be imposed only if a “total protective sentencing package” short of IPP would be insufficient (para 25–26).
• The judge’s remarks were “somewhat equivocal” (para 26). They could mean either:
  • he believed he was compelled by statute to impose IPP (which, post‑2008, would have been wrong); or
  • he appreciated that IPP was discretionary but nonetheless considered it necessary, without explaining why.

In either event, the Court held there was a material error in principle:

• If the judge thought IPP was mandatory, that was a misapprehension of the law (post‑2008 IPP was discretionary where those criteria were met).
• If he appreciated the discretion, he failed to exercise it lawfully, because:
  • he did not show that he had genuinely considered the alternative of ES; and
  • he did not explain why the second most draconian sentence was “unavoidably necessary” in the sense described in C.

The Court states emphatically (para 27):

“We can find nothing in the facts of the offending and nothing in the pre-sentence report which would provide any sufficient basis to enable the judge to conclude that an ES would not give adequate protection to the public or that the second most draconian sentence was unavoidably necessary.”

And then (para 28):

“This omission to engage with the statutory discretion or relevant authorities requiring consideration of alternatives is material and it constitutes an error in principle.”

These passages are the heart of the case. They turn C’s general guidance into a concrete rule: where both IPP and ES are available, a sentencing judge must show, on the face of the sentencing remarks, that alternatives have been considered and rejected with reasons.

5.2 Was silence about ES a mere omission, or a legal error?

An important aspect of the reasoning is that the Court of Appeal does not treat the absence of explicit reference to ES as a harmless omission:

• The respondent argued that the judge must have been aware of both IPP and ES, because he referred at the very start of the hearing to considering whether to impose a determinate or indeterminate sentence (para 21).
• The Court accepted that IPP and ES were technically available (para 23–24) but concluded that, in light of C, it was not enough to assume that the judge had silently considered ES and rejected it.
• Given the gravity of IPP, the reasons for choosing it must appear in the sentencing remarks; an appellate court should not fill in the gaps with speculation (para 26–28, 31).

Thus Zulfqar makes clear that:

• When a dangerous offender qualifies for ES, and IPP is nonetheless imposed, the absence of explicit consideration of ES and explicit reasoning in favour of IPP is itself a reviewable error in principle.
• Such error persists irrespective of the subsequent conduct of the offender or Parole Board decisions.

5.3 Risk assessment and proportionality

The Court did not disturb the finding of dangerousness (para 19). Instead it drew a proportionate link between:

• the degree of risk; and
• the least restrictive yet effective mechanism for protecting the public.

Several factors informed the Court’s view that an extended sentence would have sufficed:

• The applicant was 22 years old at the time of the offence (para 32).
• This was his first sexual offence (albeit very serious) (paras 8–9, 19).
• His risk, per the PSR, was heavily linked to:
  • alcohol misuse;
  • emotional instability; and
  • impulsivity (para 9(2)–(4)).
• The PSR did not conclude that ES was insufficient; it recommended custody with robust licence conditions (para 9(5)).
• The applicant had shown some positive response to supervision in the past and, more recently, post‑release (paras 18–19).
• The applicant would in any event be subject to:
  • long‑term (here, life‑long) sex offender registration (para 2, 34); and
  • the possibility of stringent licence conditions designed to manage risk (paras 9(5), 12, 32–34).

Thus, when the full protective package is considered — extended licence, sex offender registration, and possible ancillary orders — it was disproportionate to opt for IPP without demonstrable justification.

5.4 The re‑sentencing exercise

Having found an error in principle, the Court had to decide what sentence ought to have been imposed in 2010. It:

• Accepted that this was a very serious attempted rape case, properly in the higher guideline ranges (paras 10, 13).
• Nevertheless identified that a finite — albeit lengthy and extended — sentence would have provided adequate protection.
• Substituted an extended sentence of:
  • Custodial term: six years less one day; and
  • Extension period: five years (para 34).
• Backdated this sentence to the original date in February 2010 (para 34).

Given that the applicant had already served well in excess of six years in custody before his release by the Parole Board, the practical consequence is that:

• The custodial term was long ago completed.
• The five‑year extension period on licence, also calculated from the original sentence date, would likewise have expired by the time of this judgment.
• However, the life licence inherent in IPP was removed and replaced retrospectively by a finite extended licence, which (by 2025) had already ended. That is a substantial continuing benefit.

The Court left intact the applicant’s life‑long obligation to remain on the sex offenders’ register (para 34). The appeal was therefore not a means to escape the enduring consequences of his sexual offending, but to ensure that the custodial and licence elements of his sentence reflected the proper legal standards.

5.5 Extension of time: correcting historic injustices

The Court’s willingness to grant an extension of time of more than fourteen years is significant. Its reasons (para 32, read with paras 16–17) may be summarised:

• The original sentence was of an exceptionally severe and indeterminate nature (IPP).
• The error in principle went to the lawfulness of choosing IPP over ES, not merely to fine discretionary adjustments.
• The applicant’s delay was partly explained by:
  • early advice that no appeal lay (para 16);
  • late discovery of relevant grounds whilst in custody (para 16);
  • prison administrative failures in passing on the single judge’s refusal (para 17).
• Once properly advised and equipped with transcripts, the defence acted with reasonable promptness (para 16–17).
• Most importantly, maintaining an unlawful IPP sentence and life licence in force would perpetuate an ongoing injustice (para 32).

The Court’s language — “To avoid injustice, for these reasons, we grant the extensions of time” (para 32) — signals an approach that prioritises substantive fairness over rigid adherence to procedural time limits where the consequences of an error are grave and continuing.

6. Complex Concepts Explained

6.1 Imprisonment for Public Protection (IPP)

IPP was a type of indeterminate sentence introduced by the CJA 2003 for certain dangerous offenders. In outline:

• The judge set a minimum term (or “tariff”) — the time to be served in custody as punishment and to reflect the seriousness of the offence.
• After the minimum term, release was not automatic; it depended on the Parole Board being satisfied that it was no longer necessary for public protection that the prisoner remain confined.
• Once released, an IPP prisoner was on licence for life and could be recalled to custody at any time if risk escalated.

IPP was heavily criticised as draconian and, for new cases, was abolished by the Legal Aid, Sentencing and Punishment of Offenders Act 2012. However, many prisoners, like Mr Zulfqar, remained subject to IPP sentences imposed before abolition. Hence the continuing relevance of appeals such as this.

6.2 Extended Sentence (ES)

Under the CJA 2003 regime (as applicable in 2010), an extended sentence was a determinate sentence in two parts:

1. Custodial term
   The “appropriate custodial term” — broadly comparable to a normal determinate sentence reflecting offence seriousness, including any reduction for plea.
2. Extension period on licence
   An additional period during which the offender remained on licence in the community, subject to recall. For sexual offences, this extension could be up to eight years (para 24).

An extended sentence seeks to protect the public by lengthening the period of supervision after release without resorting to the open‑ended nature of IPP. It thus offers a powerful, but finite, structure for managing risk.

6.3 Dangerousness and specified offences

Under the CJA 2003, an offender could only receive IPP or ES if:

• he was convicted of a specified offence (a list including serious sexual and violent offences); and
• the court found him to be dangerous — meaning he posed a significant risk to members of the public of serious harm from further specified offences.

In this case:

• Attempted rape of an adult is a specified sexual offence.
• The judge found the applicant dangerous, a finding accepted on appeal (paras 14, 19).

The critical question was not whether he was dangerous, but how best to respond to that danger through sentencing.

6.4 Minimum term, licence, and life licence vs extended licence

Some key terms:

• Minimum term / tariff: In an IPP or life sentence, the minimum time the offender must serve before becoming eligible for parole.
• Licence: Conditions under which a released prisoner lives in the community; breach of conditions or escalation of risk can lead to recall to custody.
• Life licence (IPP/life sentence): The offender remains on licence for life, with the possibility of recall at any time.
• Extended licence (ES): The offender remains on licence only during the specified extension period, after which the licence ends.

In Zulfqar, the substitution of an extended sentence meant the applicant’s licence obligations for this offence would, in law, have ended years earlier than under IPP. That change in legal status justified the appeal notwithstanding his current release.

6.5 Sex offender registration

Certain sexual offences trigger automatic placement on the sex offenders’ register with associated notification requirements (such as reporting addresses, travel, etc.). The length of registration depends on the sentence and offence, but can be for life.

In this case, the applicant remains subject to lifetime registration despite the change in sentence (para 34). The Court did not and could not alter that separate regime through this appeal.

6.6 Extension of time to appeal

Normally, a convicted person must file an appeal against sentence within 28 days. The Court of Appeal has power to extend that time if it is in the interests of justice.

Relevant factors in granting an extension include:

• length of delay;
• reasons for delay (legal advice, personal capacity, institutional failures);
• the strength and significance of the proposed appeal grounds; and
• whether the sentence has ongoing serious consequences.

The Court’s decision in Zulfqar shows that even an extreme delay (over 14 years) can be overcome where:

• a serious error of law is credibly alleged and substantiated; and
• the sentence continues to have major implications (here, a life licence under IPP).

7. Impact and Significance

7.1 For sentencing judges dealing with dangerous offenders

The primary impact of Zulfqar is to reinforce, and sharpen, the principle that IPP (or any future equivalent indeterminate public protection sentence) must be treated as a measure of last resort. In practical terms:

• Where an offender is found dangerous and qualifies for both IPP and ES, the judge must:
  • identify and weigh all protective alternatives: extended licence, sex offender registration, ancillary orders (e.g. Sexual Offences Prevention Orders / Sexual Harm Prevention Orders), and stringent licence conditions; and
  • give clear reasons on the record if those measures are deemed inadequate, justifying recourse to IPP.
• Silence about extended sentence in the sentencing remarks is now positively unsafe where IPP is imposed. An appellate court is entitled — and, as this case shows, likely — to treat such silence as evidence that the C approach was not applied.
• This encourages structurally disciplined sentencing: judges must articulate their thought process, not merely assert conclusory phrases such as “the only appropriate sentence is IPP” without explaining why.

7.2 For existing IPP prisoners and late appeals

Although IPP has been abolished prospectively, a cohort of prisoners still serve historic IPP sentences. Zulfqar offers:

• a clear template for identifying appealable errors:
  • Was IPP discretionary at the time (post‑July 2008)?
  • Was an extended sentence also available?
  • Do the sentencing remarks show explicit consideration of ES and explanation of why it was inadequate?
• support for applications for very late appeals where:
  • initial legal advice was flawed or incomplete;
  • the significance of C was not appreciated at the time; and
  • the IPP sentence continues to impose a life licence and recall risk.

The decision does not guarantee success in every such case. The Court in Zulfqar made a fact‑specific judgment that, on this record, nothing justified IPP over ES. But it sets a benchmark: historic IPP sentences where neither judge nor counsel appear to have grappled with ES may be vulnerable to challenge, particularly where the offender was young and had a limited sexual history at the time.

7.3 For probation and pre‑sentence reporting

The PSR in Zulfqar contained an important legal misstatement — that the offence gave rise to a presumption of risk and eligibility for IPP (para 9(6)), which was inapplicable post‑2008. Although the judge rightly disregarded that presumption and the Court did not treat the error as decisive, the case highlights:

• the need for PSR authors to accurately state the law on dangerous offender regimes;
• the importance of explicitly addressing whether:
  • risk could be adequately managed by a determinate or extended sentence plus conditions; or
  • there is something about the offender or pattern of offending that truly requires indeterminate detention.

Well‑reasoned PSRs that engage with the full menu of disposals will aid judges in meeting the obligations reinforced in Zulfqar.

7.4 For public protection and penal policy

More broadly, the decision underscores:

• that public protection does not invariably require indeterminate detention; robust, extended, and well‑monitored supervision in the community can often provide a proportionate alternative;
• the importance of viewing risk management as a package: custody, licence, therapeutic work, monitoring orders, and registration regimes must all be considered in the round;
• the judiciary’s continuing role in scrutinising historic sentences that remain in force long after the legislative framework that created them has changed.

In policy terms, Zulfqar supports a move away from unexamined reliance on indeterminate sentences in favour of structured, transparent, and proportionate approaches to managing dangerous offenders.

8. Conclusion

R v Zulfqar [2025] EWCA Crim 1683 is a significant reaffirmation and refinement of the principles governing the imposition of imprisonment for public protection. The Court of Appeal holds that:

• IPP — the most severe sentence short of life imprisonment — must be treated as an exceptional last resort.
• Where an extended sentence and other protective measures are available, the sentencing judge must:
  • actively consider them; and
  • provide clear, reasoned justification on the record if they are rejected in favour of IPP.
• The absence of such reasoning is a material error in principle, capable of vitiating the sentence even many years after it was passed.
• Appellate courts retain a strong interest in correcting such errors “to avoid injustice”, including by granting very substantial extensions of time in suitable cases.

By quashing an IPP imposed on a 22‑year‑old offender for a single, though extremely grave, attempted rape, and substituting a long but finite extended sentence, the Court both vindicated the guidance in Attorney General’s Reference No 55 of 2008 and offered a pathway for the principled review of historic IPP sentences. The case stands as a clear reminder that the pursuit of public protection must be balanced by proportionality, legality, and transparency in sentencing.