The scheme of the Criminal Justice Act 2003 Sch.21 was that the trial judge had first to determine the starting point and then consider whether it was appropriate to adjust the sentence upwards or downwards to take account of aggravating or mitigating factors. That approach was not possible in respect of a whole life order. A whole life order should be imposed where the seriousness of the offending was so exceptionally high that just punishment required the offender to be kept in prison for the rest of his life.

[2005] EWCA Crim 3115