Three men jailed under IPP and DPP sentences could have their cases reconsidered on appeal
IPP sentence referrals are at the centre of the Criminal Cases Review Commission‘s latest decision to refer three more indeterminate sentence cases to the Court of Appeal, continuing its ongoing review of Imprisonment for Public Protection (IPP) and Detention for Public Protection (DPP) cases.
The Criminal Cases Review Commission (CCRC) announced on 4 August 2026 that it has referred the indeterminate sentences of three men who were sentenced between 2006 and 2008. Although none of them received minimum tariff periods exceeding four years, all remain in custody today.
The referrals form part of the Commission’s thematic review of IPP and DPP sentences. According to the CCRC, it has now referred 14 IPP cases to the Court of Appeal during 2026, while approximately 200 further IPP and DPP cases remain under active review by its casework teams.
One of the cases concerns Richard Lloyd, who was convicted at Coventry Crown Court in May 2008 of sexual assault, attempted rape, affray, theft, assault by beating, common assault, actual bodily harm and witness intimidation. Aged 26 at the time of sentencing, he received an IPP sentence with a minimum tariff of 37 months, less 232 days already spent on remand.
Mr Lloyd was released from custody in July 2019 before being recalled in July 2020. He remains in custody and submitted an application to the CCRC in March 2025.
The second referral involves Christian Chambers. In June 2006, he was convicted of robbery, attempted robbery and possession of an imitation firearm. He received a sentence of Detention for Public Protection (DPP) with a minimum term of two years, reduced by 48 days spent on remand.
The robbery offence was committed in May 2004 when Mr Chambers was 15 years old, while the remaining offences took place in February 2006 when he was 17. He has never been released from custody and remains subject to his DPP sentence. His application to the CCRC was received in October 2024.
The third case relates to Marlon Chen, who was aged 25 when he was convicted at the Central Criminal Court in September 2006 of possessing a firearm with intent to endanger life. He received an IPP sentence with a minimum tariff of four years, less 384 days spent on remand.
Mr Chen was released in March 2020 but was recalled to prison in 2022 following his arrest and conviction for further firearms offences. He remains in custody and applied to the CCRC in September 2025.
In reviewing the three cases, the Commission considered the impact of recent Court of Appeal judgments, particularly R v Williams [2024] EWCA Crim 686 and R v Davis & Others [2026] EWCA Crim 743. The CCRC concluded that there is a real possibility the Court of Appeal would now determine that the original sentencing judges did not give sufficient weight to each applicant’s age and level of maturity when assessing dangerousness and future risk.
The Commission noted that the Court of Appeal has recently overturned several comparable indeterminate sentences. On 23 April 2026, two CCRC referrals were allowed, with those sentences being quashed alongside three other IPP and DPP cases.
CCRC Chair Dame Vera Baird KC said the latest referrals demonstrate the Commission’s continuing commitment to ensuring that people serving indeterminate sentences benefit where significant developments in Court of Appeal case law may affect their cases.
She said the three men remain in prison despite having been sentenced between 2006 and 2008 and noted that the Court of Appeal has made clear that the relationship between a person’s age, maturity and assessment of future dangerousness requires careful consideration. Where there is a real possibility those principles were not properly applied, she said, the Commission will refer the case for a fresh appeal.
Dame Vera Baird KC also said the CCRC is progressing these reviews as quickly as possible despite its substantial caseload and welcomed the fact that referred cases appear to be listed promptly by the Court of Appeal.
IPP sentences were introduced for offenders considered to present a serious risk to the public, while DPP sentences applied similar principles to offenders under the age of 18. Both sentencing regimes were abolished in 2012. However, people sentenced before abolition remain subject to the terms of their original sentences, and referrals by the CCRC do not alter those sentences unless the Court of Appeal subsequently decides they should be changed.