The imposition of a tariff which was possibly higher than that which the prisoner would have received had he remained in Scotland rather than being transferred to an English prison was not a violation of the priosner's rights under the European Convention on Human Rights Art.7 as the penalty which should have been compared was that of life imprisonment; the tariff set the minimum period to be served in prsion.

[2003] EWHC 1542 (Admin)