In the light of the Practice Statement on Life Sentences [2002] 1 WLR 1789, a judge had to go through four steps in order to reach a conclusion in relation to a minimum term. First he had to fix a starting point; secondly, he had to consider the aggravating circumstances; thirdly, he had to consider the mitigating circumstances and fourthly, he had to deduct any time spent on remand.

[2003] EWCA Crim 309