The recall of a prisoner for breach of licence conditions, pursuant to provisions enacted between the commission of the original offence and sentencing, did not amount to an additional liability imposed in breach of the European Convention on Human Rights 1950 Art.7, as that issue had been determined by the case of R. (on the application of Uttley) v Secretary of State for the Home Department (2004) UKHL 38 by which the court was bound.

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