Although the Criminal Justice Act 2003 Sch.21 provided a series of criteria to be taken into account when the court was determining the appropriate minimum term in relation to mandatory life sentences to reflect the "seriousness" of the individual offence, the court was not rigidly bound by or limited to considering the aggravating factors listed in Sch.21 para.10 and mitigating factors listed in Sch.21 para.11. The true seriousness of the offence inevitably represented a combination, and simultaneously, a balancing of all relevant factors in the case.

[2005] EWCA Crim 605