On an appeal by a prisoner sentenced to a mandatory sentence of life imprisonment with the minimum term to be determined pursuant to the provisions relating to transitional cases, contained in Schedule 22 to the Criminal Justice Act 2003, a reduction in the length of the minimum term could take account of exceptional progress made by the prisoner. Possible reductions for exceptional progress in prison did not, however, form part of any appeal process for sentences imposed after December 18, 2003.

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