On a December day in 1997, a judge in Pretoria sentenced Moses Sithole to 2,410 years in prison and ordered that he serve at least 930 of them before anyone could consider him for parole. A decade later, in a courtroom in central Portugal, a prosecutor asked the judges to give António Luís Costa the most they could, and explained the figure in a single phrase: twenty-five years, because there is no more. Both men had killed more than once. One sentence ran centuries past any human life; the other was the ceiling of an entire legal system. Neither number, by itself, says when the prisoner leaves.
That is the trouble with the figures that close a murder trial. A court pronounces a sentence in the vocabulary of its own law, and that vocabulary does not translate. "Life" means twenty years in one country and the rest of a man’s days in another. A sentence measured in centuries can sit beside a statute that caps the time served at a fraction of it. The gap between the sentence and the release date is where the real punishment is decided, and in each of the eleven countries that follow it is decided by a different rule.
Sithole was convicted in the Pretoria High Court of 38 murders, with other charges, committed around Pretoria and the East Rand in 1994 and 1995. Judge David Curlewis imposed sentences that SA People, reporting in November 2025, put at a total of 2,410 years, with a minimum of 930 years to be served before parole could be considered. The death penalty was already gone: in June 1995 the Constitutional Court had ruled in S v Makwanyane that capital punishment was cruel, inhuman and degrading. Curlewis disagreed openly, and a Mail & Guardian editorial of December 12, 1997, criticized his public remarks in the case. As of November 2025, Sithole was held in the C-Max section of the Kgoši Mampuru II prison in Pretoria.
Bulelani Mabhayi, a builder from Tholeni village near Butterworth in the Eastern Cape, pleaded guilty in 2013 to 20 counts of murder, with other charges, covering killings between 2007 and 2012. Acting Judge Noluthando Conjwa, sitting for the Mthatha High Court, sentenced him to 25 life terms. The Star reported that the terms would run concurrently; the government news agency SAnews put the total at 625 years.
The figures are statements of condemnation. The release rule lives in a different statute. Section 73(6) of the Correctional Services Act, in the form Parliament enacted in the Correctional Services Amendment Act of 2021, says that an offender serving life for an offense committed after the relevant chapters of the act came into force may not be placed on parole until he has served at least 25 years. For an offender serving a fixed sentence or cumulative sentences of more than two years, it requires the stipulated non-parole period or half the sentence to be served first, and then adds a sentence that cuts across every figure a court can pronounce: parole "must be considered" whenever an offender has served 25 years of a sentence or cumulative sentences. The same provisions tie their rules to offenses committed after a stated commencement, and older crimes fall under the act’s transitional provisions.
Alfredo Galán, a former army corporal from Puertollano, killed six people in the Madrid region between January and March 2003 and tried to kill three others. In March 2005 Section 16 of the Audiencia Provincial de Madrid convicted him and sentenced him to 142 years and three months. The same judgment, as the Diario de León reported on March 10, 2005, fixed a maximum effective term of 25 years and ordered that prison benefits and the time needed for parole be calculated on the total of the sentences rather than on the capped figure.
The cap is a feature of Spanish law, not a concession to the defendant. Article 76 of the Criminal Code limits the time a prisoner may actually serve for accumulated sentences. Organic Law 7/2003, in force from July 2, 2003, a few months after Galán’s last killing, rewrote that article: the general limit stayed at 20 years, with exceptional limits of 25 and 30 years, and a new limit of 40 years where at least two of the crimes each carried more than 20 years, or for two or more terrorist crimes. The law’s preamble said certain offenses, by their gravity, demanded "a more forceful response." In 2015 Spain added a sentence it had not had before, permanent reviewable imprisonment. Under Article 92, in the code as consolidated in April 2015, a court must suspend it once the prisoner has served 25 years, has reached the pre-release stage of prison treatment and receives a favorable assessment of his prospects of reintegration.
Galán’s case was never governed by that newer sentence. In January 2023, on the twentieth anniversary of the first killing, Castilla-La Mancha Media reported that every request he had made for prison leave had been refused and that his release was expected around 2028. In March 2026 Telecinco said he was still in prison and could be freed around 2028, on completing 25 years.
Raúl Osiel Marroquín, a former soldier from Tamaulipas, was convicted in Mexico City of kidnapping and murdering four men. In October 2006 he received 60 years for one killing. In May 2007, La Jornada reported, a second judgment added 147 years for two more killings and the kidnappings that went with them, and a later judgment covered a fourth death. The totals in the press vary: Infobae put the sum at 280 years in 2020, 2021 and 2022, El Telégrafo at 288 and El Heraldo de México at more than 290. In September 2022 Infobae reported him held in the Santa Martha Acatitla penitentiary.
The penal code of Mexico City, as reformed to December 31, 2018, sets the length of a prison term at between three months and seventy years. Article 33 adds that where two or more prison terms come from different judgments, they are served one after another, "without the sum of them being greater than seventy years." Article 79, on multiple offenses tried together, allows the penalty for the most serious crime to be increased by the others, but not beyond the maximum in Article 33.
Portugal goes further than any of the other ten countries in refusing open-ended punishment. Article 24 of its Constitution bars the death penalty in all cases, and Article 30 forbids any sentence or security measure depriving a person of liberty that is perpetual or of unlimited duration. The Penal Code sets the maximum prison term at 20 years, raises it to 25 years in the cases the law provides, and states that the 25-year limit may never be exceeded.
António Luís Costa, a retired corporal of the Guarda Nacional Republicana from the Santa Comba Dão area, was arrested in June 2006 over the deaths of three young women he had known since they were children. On July 31, 2007, the court in Figueira da Foz convicted him of three homicides, with other charges, and imposed 25 years. The prosecutor, Jorge Leitão, had asked for exactly that, telling the court, as the Jornal de Notícias reported, that it was 25 years "because there is no more" and that the defendant deserved more. The Coimbra Court of Appeal and the Supreme Court of Justice dismissed his appeals in 2008.
Article 61 of the Penal Code then governs release. A prisoner serving more than six years is placed on conditional release once he has served five-sixths of the sentence, regardless of the earlier points at which release may be granted. Costa left prison for the first time on a three-day leave from Évora on May 31, 2021, a visit that left his victims' relatives, Jornal do Centro reported, in shock. On August 31, 2026, the Diário de Viseu, citing the broadcaster SIC, reported that he would be released in April 2027.
Charles Sobhraj, a French citizen born in Saigon, was arrested in a Kathmandu casino in September 2003 and charged with two killings in the Kathmandu Valley in December 1975. On August 12, 2004, the Kathmandu District Court convicted him of the murder of Connie Jo Bronzich, an American traveler, and sentenced him to life imprisonment. In Nepal at that time a life sentence was a term of 20 years. A second Nepali court convicted him in 2014 of the murder of Laurent Carrière, a Canadian, and The Kathmandu Post later described him as serving two concurrent 20-year terms.
On December 21, 2022, a division bench of the Supreme Court of Nepal ordered the government to free him. The Himalayan Times reported that the court applied the rule allowing prisoners over 65 to have up to 75 percent of their sentence waived for good conduct, rejected the jail administration’s argument that the benefit belonged only to Nepali citizens, and noted that the Central Jail had twice recommended a reduction. He was released on December 23, 2022, after 19 years, three months and seven days, put on a flight to France the same evening and barred from returning to Nepal for ten years, The Kathmandu Post reported. In August 2023 he gave an interview in Paris to Al Jazeera.
The law has moved since. The National Penal Code that took effect in August 2018 raised the standard life sentence from 20 years to 25, The Kathmandu Post reported on August 25, 2026, and created a separate sentence for six categories of aggravated homicide: imprisonment for the rest of the offender’s natural life, with no possibility of release. Once that verdict is final, the paper reported, Nepalese law provides no mechanism to reconsider it, and a study commissioned by the Attorney General’s office has proposed letting district courts review such sentences after 30 years.
Russia carried out its last execution in 1996, the year it joined the Council of Europe and pledged to stop. The Criminal Code that took effect on January 1, 1997, allowed death to be replaced by life imprisonment or by 25 years. On February 2, 1999, the Constitutional Court barred death sentences until jury trials existed throughout the country, and on November 19, 2009, it ruled that the bar held even after juries had been established, extending the moratorium until Russia ratified Protocol No. 6 of the European Convention. A life prisoner becomes eligible for parole after 25 years; according to Federal Penitentiary Service figures for 2022 cited by TASS in March 2024, 1,942 people were serving life.
Alexander Maslich was already a prisoner when he was sentenced to death in July 1995 for killing a fellow inmate at Rubtsovsk in the Altai region, Interfax reported through The Moscow Times; Interfax, in a dispatch printed by The Spokesman-Review, called him Andrei. In December 1996 the Altai regional court sentenced him to death a second time, for killing a cellmate in Barnaul. Neither sentence was carried out. Altapress, the Barnaul publisher, reported in 2021 that his death sentence had been commuted to life and that he died in 2015 in the special-regime colony at Sol-Iletsk in Orenburg region known as the Black Dolphin; the cause of death was not reported.
Vladimir Mukhankin pleaded guilty in Rostov-on-Don and was sentenced to death in January 1997 for murdering eight people, The Moscow Times reported. The sentence was later commuted to life imprisonment. In an interview with RT, Amurkhan Yandiev, a retired investigator who worked on the Chikatilo case, described Mukhankin as serving it at the Black Dolphin.
French law separates the sentence from the period during which no release of any kind is possible. That second period, the période de sûreté, is the number that matters. In an answer published on December 27, 2012, to a written question from Senator Louis Nègre, the Ministry of Justice set out the rules: for certain of the most serious crimes the code fixes the security period automatically at 18 years when life is imposed, and the assize court may raise it to 22 years or reduce it. For certain murders, including some murders of minors and of public officials, Articles 221-3 and 221-4 of the Penal Code allow the court to order that no measure of release may ever be granted. Even that sentence can be revisited: under Article 720-4 of the Code of Criminal Procedure, after 30 years in prison and an examination by three medical experts on the prisoner’s dangerousness, the sentence-enforcement court may end the bar. The ministry stressed that this frees no one. It only allows the prisoner to apply for conditional release.
Guy Georges was sentenced by the Paris assize court on April 5, 2001, to life imprisonment with a 22-year security period for the murders of seven young women in Paris between 1991 and 1997. Europe 1 reported in 2015 that he would be eligible to apply for release from 2020. Newsweek placed him at the maison centrale of Ensisheim, in Alsace, in September 2021.
Patrice Alègre received the same sentence, life with a 22-year security period, from the Haute-Garonne assize court in Toulouse in February 2002, for five murders, with other charges. In September 2019, The Local reported, he was held at Moulins, in the Allier, and his lawyer was preparing an application for conditional release.
Michel Fourniret received the sentence those two did not. On May 28, 2008, the Ardennes assize court at Charleville-Mézières convicted him of seven murders, with other charges, committed in France and Belgium between 1987 and 2001, and imposed life with no possibility of release, the sentence the French press calls perpétuité incompressible. In November 2018 the assize court at Versailles added a second life sentence for another murder. Fourniret died in custody on May 10, 2021, at 79, Agence France-Presse reported, while still under investigation in other cases.
In Canada a sentence of life for murder lasts for life. What the judge sets is the period before the prisoner may apply for parole, and for first-degree murder that period is 25 years. Clifford Olson pleaded guilty in January 1982 in British Columbia to 11 counts of first-degree murder and received 11 concurrent life sentences with no parole eligibility for 25 years. The law then included the "faint hope" clause, Section 745 of the Criminal Code, which let a lifer ask a jury after 15 years to shorten the wait. Olson’s hearing began in Surrey in August 1997; the jury rejected his application in about 15 minutes, CBC News reported. Parliament had already amended the clause in January 1997 to bar people convicted of multiple murders after that date, Maclean’s reported. The National Parole Board denied Olson parole on July 18, 2006, CBC reported, and again on November 30, 2010, according to CTV News. He died of cancer in federal custody in Quebec on September 30, 2011.
Robert Pickton was convicted in New Westminster in December 2007 of six counts of second-degree murder. Second-degree murder carries a mandatory life sentence with a parole ineligibility period of 10 to 25 years, and on December 11, 2007, Justice James Williams imposed the maximum, CTV News reported. On February 22, 2024, Pickton became eligible to apply for day parole. The Parole Board of Canada pointed out that eligibility did not mean a hearing, and none had been scheduled, Global News reported. He was assaulted by another inmate at Port-Cartier Institution in Quebec on May 19, 2024, and died on May 31, the Correctional Service of Canada announced.
John Martin Crawford, convicted in 1996 of one first-degree and two second-degree murders near Saskatoon after an earlier manslaughter conviction in Alberta, died in custody at the Regional Psychiatric Centre in Saskatoon on December 16, 2020, the Correctional Service of Canada said.
Section 745.51 of the Criminal Code, added in 2011, had let judges stack the 25-year periods for multiple murders one after another. In 2022, in R v Bissonnette, the Supreme Court of Canada unanimously struck down that power as cruel and unusual punishment under Section 12 of the Charter. A sentence of life with no realistic possibility of parole before death, the court held, is degrading and incompatible with human dignity, because it denies the offender any chance of returning to society. The provision was declared of no force or effect from the day it was enacted.
Murder in England and Wales carries a mandatory life sentence, and a person released from one spends the rest of his life on licence and can be recalled to prison, as the government’s own guidance puts it. What varies is the minimum term the judge fixes, and Schedule 21 of the Sentencing Act 2020, as in force in October 2026, sets the starting points. Most adult murders begin at 15 years; a case of particularly high seriousness begins at 30. Where seriousness is exceptionally high and the offender was 21 or over, the starting point is a whole life order. The schedule lists, among the cases that normally qualify, the murder of two or more people where each involves substantial premeditation, abduction or sexual or sadistic conduct, and the murder of a child involving abduction or a sexual or sadistic motive. A whole life order, in the government’s words, means the prisoner will never be released except in exceptional compassionate circumstances.
Levi Bellfield, a former doorman and wheel-clamper from west London, was convicted at the Old Bailey in February 2008 of murdering Marsha McDonnell, 19, and Amelie Delagrange, 22, and of trying to kill a third young woman, who survived. He refused to come to court for sentence, and on February 26, 2008, Mrs Justice Rafferty imposed a whole life order in his absence. In June 2011 a second jury convicted him of kidnapping and murdering Milly Dowler, 13, who had disappeared on her way home from school in Walton-on-Thames in March 2002. On June 24, 2011, Mr Justice Wilkie imposed a second whole life order, again without Bellfield in the dock, and Channel 4 News reported that he was thought to be the first person ever given two. After he applied to marry in prison, the government moved to close the door: from August 2, 2024, under the Victims and Prisoners Act, prisoners serving whole life orders could no longer marry or enter civil partnerships, and ITV News reported that Bellfield had been blocked from a civil partnership under the new law.
Australian courts sentencing for serious crimes usually fix two numbers: the head sentence and a non-parole period, after which the prisoner may be released on parole. In South Australia, the Legal Services Commission’s Law Handbook explains, a court imposing a sentence of a year or more must fix a non-parole period unless it considers there is good reason not to. Where a court declines, there is no date on which the prisoner may apply at all.
In the Snowtown case, the killings of 11 people in and around Adelaide between 1992 and 1999, the Supreme Court of South Australia showed both outcomes in the same courtroom. Robert Joe Wagner pleaded guilty to three murders and was convicted by a jury of seven more on September 8, 2003; John Bunting was convicted of 11. Justice Brian Martin sentenced both men to life imprisonment and declined to fix a non-parole period for either. In 2019 Wagner, then 47, applied in a handwritten letter to have one set. On May 9, 2019, Justice Greg Parker dismissed the application, describing the killings as the worst crimes ever detected in the state, the ABC reported, and holding that punishment and deterrence required that no period be fixed.
James Vlassakis, Bunting’s stepson, pleaded guilty to four of the murders and gave evidence against the other two. Justice Kevin Duggan sentenced him to life with a non-parole period of 26 years, and said that without his pleas and cooperation it would have been 42. The Parole Board granted him parole in 2025; a review overturned the decision that December, and in September 2026 his parole was confirmed, the ABC reported. Reporting in October 2026 on his first days outside, The New Daily described Bunting and Wagner as still serving life without parole.
Japan’s Penal Code, as amended to 2017, allows a prisoner serving life to be paroled after 10 years if he shows signs of substantial reformation. Death is carried out by hanging in a penal institution, and the prisoner is held in custody until the day it comes. Since the mid-1970s, TIME reported in April 2024, prisoners have usually been told of their execution one to two hours beforehand, and families are told afterward. On April 15, 2024, a district court in Osaka dismissed a lawsuit by death row inmates challenging the practice without ruling on whether it was constitutional. At the end of March 2024, 109 people were under sentence of death.
Tsutomu Miyazaki, a photo technician from western Tokyo, was sentenced to death by the Tokyo District Court in April 1997 for the murders of four young girls, with other charges, in Saitama Prefecture and Tokyo in 1988 and 1989. His lawyer, Maiko Tagusari, later wrote that she had been preparing a request for a retrial and had written to Justice Minister Kunio Hatoyama on May 30, 2008, asking that he not be executed. He was hanged at the Tokyo Detention House on June 17, 2008, on Hatoyama’s order, and Tagusari wrote that her client had been executed without notice to her.
Kanae Kijima was convicted by a lay judge panel at the Saitama District Court on April 13, 2012, of murdering three men, with other charges, and sentenced to death, Agence France-Presse reported. She denied the killings throughout. On April 14, 2017, Japan’s Supreme Court rejected her final appeal. In November 2024 the weekly Shukan Josei reported her held at the Tokyo Detention House.
Set side by side, the cases separate cleanly into two kinds of sentence. In one kind the figure is a ceiling or a starting gate written into statute, and the court’s number is a statement on top of it: Galán’s 142 years under a 25-year limit, Marroquín’s centuries under a code that stops at 70, Mabhayi’s 25 life terms beside a 25-year parole rule, Sobhraj’s life term that was 20 years by definition and ended early by remission. In the other kind the decisive figure is the one the court declines to give: no non-parole period for Wagner and Bunting, no security period with an end for Fourniret, a whole life order for Bellfield.
Costa’s case stands apart. Portugal has written the ceiling into its constitution, and a prosecutor who wanted more could only ask for 25 years and say plainly that there was nothing beyond it. Sithole’s 930 years points the other way, a figure that measures nothing a prison can count. Between those two poles sit the other nine countries, and in each the honest answer to the question of how long a killer will serve begins with a statute, not a sentence.
• January 1982: Clifford Olson pleads guilty in British Columbia to 11 counts of first-degree murder; 11 concurrent life sentences, no parole for 25 years.
• June 1995: South Africa’s Constitutional Court rules capital punishment unconstitutional in S v Makwanyane.
• July 1995: Alexander Maslich sentenced to death in the Altai region; a second death sentence follows in December 1996.
• 1996: Russia joins the Council of Europe and carries out its last execution.
• January 1, 1997: Russia’s new Criminal Code takes effect, allowing death to be replaced by life or 25 years.
• January 1997: Vladimir Mukhankin sentenced to death in Rostov-on-Don; Canada’s Parliament amends the faint-hope clause.
• August 1997: a jury in Surrey, British Columbia, rejects Olson’s faint-hope application.
• December 1997: Moses Sithole sentenced in Pretoria to a total of 2,410 years, with no parole consideration for 930.
• February 2, 1999: Russia’s Constitutional Court bars death sentences until jury trials exist nationwide.
• April 5, 2001: Guy Georges sentenced in Paris to life with a 22-year security period.
• February 2002: Patrice Alègre sentenced in Toulouse to life with a 22-year security period.
• July 2, 2003: Spain’s Organic Law 7/2003 takes effect, raising the limits on time served for accumulated sentences.
• September 8, 2003: Robert Joe Wagner and John Bunting convicted in Adelaide; both later sentenced to life with no non-parole period.
• August 12, 2004: Charles Sobhraj convicted in Kathmandu of the murder of Connie Jo Bronzich and sentenced to life.
• March 2005: Alfredo Galán sentenced in Madrid to 142 years and three months, with an effective limit of 25 years.
• May 2007: Raúl Osiel Marroquín receives 147 years in a second Mexico City judgment.
• July 31, 2007: António Luís Costa sentenced in Figueira da Foz to 25 years.
• December 11, 2007: Robert Pickton sentenced to life with no parole eligibility for 25 years.
• February 26, 2008: Levi Bellfield receives his first whole life order.
• May 28, 2008: Michel Fourniret sentenced at Charleville-Mézières to life with no possibility of release.
• June 17, 2008: Tsutomu Miyazaki hanged at the Tokyo Detention House.
• November 19, 2009: Russia’s Constitutional Court extends the moratorium on the death penalty.
• June 24, 2011: Bellfield receives a second whole life order.
• September 30, 2011: Olson dies in federal custody in Quebec.
• April 13, 2012: Kanae Kijima sentenced to death in Saitama.
• 2013: Bulelani Mabhayi sentenced to 25 life terms.
• 2014: Sobhraj convicted in Nepal of the murder of Laurent Carrière.
• April 14, 2017: Japan’s Supreme Court rejects Kijima’s final appeal.
• August 2018: Nepal’s National Penal Code takes effect, raising the standard life sentence from 20 to 25 years.
• May 9, 2019: Wagner’s application for a non-parole period dismissed.
• December 16, 2020: John Martin Crawford dies in custody in Saskatoon.
• May 10, 2021: Fourniret dies in custody.
• May 31, 2021: Costa leaves prison on his first three-day leave.
• June 1, 2021: South Africa’s Correctional Services Amendment Act 7 of 2021 published in the Government Gazette.
• 2022: Canada’s Supreme Court strikes down consecutive parole ineligibility periods in R v Bissonnette.
• December 23, 2022: Sobhraj released in Kathmandu and deported to France.
• February 22, 2024: Pickton becomes eligible to apply for day parole; he dies on May 31, 2024, after an assault in prison.
• April 15, 2024: an Osaka district court dismisses death row inmates' challenge to same-day execution notice.
• August 2, 2024: prisoners serving whole life orders in England and Wales barred from marrying or entering civil partnerships.
• March 2026: Galán reported still in prison, with release expected around 2028.
• August 31, 2026: Costa reported due for release in April 2027.
• September 2026: James Vlassakis’s parole confirmed in South Australia.