Ten days after Myra Hindley died in custody, the House of Lords ruled that a Home Secretary could no longer decide how long a convicted murderer must stay in prison. The power had been the one that kept her there. For close to two decades ministers, not judges, had fixed the minimum term for every prisoner serving a life sentence, and for a very small number of prisoners the number they chose was no number at all. The whole life order, as it is now called, was made by a politician before it was made by a court. How it moved from one to the other, who tried to break it, and who in the last twenty years has actually been given one, runs through ten cases.
Hindley was convicted at Chester Assizes on May 6, 1966, of the murders of Lesley Ann Downey, 10, and Edward Evans, 17, and of harboring her partner Ian Brady knowing that he had murdered John Kilbride, 12. Brady was convicted of all three murders. Both received life sentences, and the judge had no choice about it: the death penalty for murder had been abolished while they were on remand, and the Murder (Abolition of Death Penalty) Act 1965 had replaced it with a mandatory life term. Mr. Justice Fenton Atkinson drew a line between the two. Brady, he said, was "wicked beyond belief without hope of redemption (short of a miracle)". He did not think the same was necessarily true of Hindley once she was removed from Brady’s influence, though he expected her to be kept in prison for a very long time.
A life sentence for murder then carried no fixed minimum. From 1983 the Home Secretary set a "tariff" for each life-sentenced prisoner, the period to be served for retribution and deterrence before release could be considered; Leon Brittan announced the system to the House of Commons on November 30, 1983, as the House of Lords later recorded. In Hindley’s case a minimum of 25 years was suggested in 1982. In March 1985 Brittan made what the Lords called a provisional decision, which a later review gives as 30 years. She was not told. In 1990 another Home Secretary, David Waddington, reconsidered the file and decided on a whole-life tariff: she should never be released. She was not told that either. She learned of both decisions in 1994.
In 1987 Hindley had admitted taking part in the deaths of Pauline Reade, 16, and Keith Bennett, 12. She was never charged or tried over either. Her confession changed how the Home Office saw her. In early 1997 the Parole Board recommended that she be moved to open conditions; the Home Secretary rejected it. On February 3, 1997, Michael Howard decided on a whole-life tariff and told her so, and on November 19, 1997, his successor Jack Straw wrote that he saw no reason to depart from that conclusion, while leaving open whether her progress in prison might one day justify a reduction. A MORI poll that year put public opposition to her release at 83 percent.
Her lawyers set out nine arguments. A whole-life tariff, they said, was inconsistent with the statutory idea of a life sentence. The policy unlawfully tied the Home Secretary’s hands and shut out the Parole Board. The 1985 provisional figure had been unlawfully increased. She had a legitimate expectation of a finite term. And her mitigation had been ignored: she was 22 and 23 at the time, Brady had dominated and threatened her, and she had already served 34 years. The Divisional Court dismissed the application on December 18, 1997. Lord Bingham, the Lord Chief Justice, said he could see no reason in principle why crimes wicked enough should not be punished by imprisonment for life. The Court of Appeal dismissed her appeal on November 5, 1998, treating it as a test case for other prisoners with whole-life tariffs, but gave leave to go further.
On March 30, 2000, five Law Lords (Browne-Wilkinson, Nicholls, Steyn, Hutton and Hobhouse) dismissed the appeal unanimously. Lord Steyn gave the leading speech. A whole-life tariff was lawful, he held, subject to the Home Secretary’s continuing power to review it. The 1985 decision had never been communicated and could not ground a complaint. She had no legitimate expectation of a fixed term. The Home Secretary had assumed, without deciding, that her account of threats from Brady was true, and his treatment of her mitigation was rational. "Her role in the murders was pivotal," Lord Steyn said. The case is reported as R v Secretary of State for the Home Department, ex parte Hindley [2000] UKHL 21.
She died in custody in November 2002. Ten days after her death the House of Lords gave the ruling on ministerial tariff-setting that Statewatch reported that month under the headline "Home Secretary’s tariff setting violates fair trial". The Home Secretary could no longer fix the minimum term of a convicted murderer.
Peter Moore, who owned a small chain of cinemas in North Wales, was convicted on November 29, 1996, of four counts of murder. The four men had died in Anglesey, Denbighshire and near Abergele between September and December 1995. He had confessed to police at Llandudno in the early hours of Christmas Eve, including to a death police had not known about, and withdrew the confession the next morning. After a jury trial the judge passed the mandatory life sentence and recommended that Moore never be released. The Lord Chief Justice, reviewing the file, advised 30 years. On September 27, 2002, the Secretary of State set a whole-life tariff, the European Court of Human Rights recorded.
That was the old system working as designed: the trial judge and the Lord Chief Justice each sent a view to the minister, and the minister decided. Section 276 of and Schedule 22 to the Criminal Justice Act 2003 changed it by allowing prisoners whose tariffs a minister had set to apply to the High Court for a review. Moore applied, and on June 12, 2008, the High Court declined to adopt the Lord Chief Justice’s 30 years. It held that the recommendation deserved weight but that the Lord Chief Justice had not applied the principles of Schedule 21 to the 2003 Act, which the High Court was bound to apply. Under Schedule 21 the case called for a whole-life starting point, because it involved two or more murders, sexual or sadistic conduct and a substantial degree of premeditation. The court identified no mitigating features. It added that even a 30-year starting point would have been outweighed by the aggravating features, and it made a whole life order. The court also rejected his human rights arguments, holding that the review procedure gave him the independent hearing that Article 6 requires and that the order was compatible with Articles 3 and 5.
On February 26, 2009, the Court of Appeal dismissed his appeal, holding that the High Court had been not merely entitled but plainly right. His effort to reach the House of Lords stalled on a technicality: on August 14, 2009, the Criminal Appeal Office told him the court had refused permission to appeal against sentence, so there was no dismissed appeal on which a point of law could be certified.
Moore then took the case to the European Court of Human Rights, where it was joined with the applications of Douglas Vinter and Jeremy Bamber as Vinter and Others v. the United Kingdom. All three argued that a sentence with no prospect of release was inhuman and degrading under Article 3. On January 17, 2012, a Chamber of seven judges rejected them by four votes to three. In Moore’s case it held that his continued detention still served the legitimate purposes of punishment and deterrence, and it rejected his complaint under Article 5, paragraph 4, as manifestly without merit. Judges Garlicki, Bjorgvinsson and Nicolaou dissented in part: to them, the lack of any mechanism to review a whole life sentence was itself a breach of Article 3, because it left the prisoner without hope. The Justice Secretary, Kenneth Clarke, said the government had fought the case "vigorously", and a Ministry of Justice spokesman said it strongly welcomed the decision.
A panel of five judges accepted the case for the Grand Chamber on July 9, 2012, and the hearing took place in Strasbourg on November 28, 2012. On July 9, 2013, the Grand Chamber of 17 judges ruled by 16 votes to one that the whole life sentences of all three men breached Article 3. A life sentence, it held, must be reducible: there had to be both a prospect of release and a possibility of review, so that the authorities could ask whether a prisoner had changed so much that continued detention could no longer be justified. The court noted clear support in comparative and international law for a first review no later than 25 years into the sentence.
The ruling changed nothing for Moore’s release. What it started was an argument between the British courts and Strasbourg that ran until 2017. In February 2014 the Court of Appeal returned to the question in R v McLoughlin and R v Newell, and Mr. Justice Spencer relied on that decision when he sentenced Joanna Dennehy ten days later. The Grand Chamber came back to the subject in Hutchinson v. the United Kingdom on January 17, 2017. Moore himself was reported as a Category A prisoner at HMP Wakefield in September 2020.
Levi Bellfield’s sentences are the plainest example of what a judge, rather than a minister, now does with the power. A west London wheel-clamper and former doorman, he was convicted at the Old Bailey in February 2008 of murdering Marsha McDonnell, 19, and Amelie Delagrange, 22, and of the attempted murder of Kate Sheedy, 18. He refused to come to court for sentencing on February 26, 2008. His lawyer said he was staying away because of publicity about his conviction and because he was upset at being linked to other crimes. Mrs. Justice Rafferty imposed a whole life order, meaning he would never be considered for parole. "You have reduced three families to unimagined grief," she said, and she praised the jurors as "twelve sensible individuals" who had seen through his defenses. Reuters reported that he received the order on each of the two murders and the attempted murder; other reports said a single order. All agreed that he was told he would never be released.
In June 2011 a second jury convicted him of the kidnapping and murder of Milly Dowler, 13. He again refused to attend. On June 24, 2011, Mr. Justice Wilkie imposed another whole life order, called Bellfield a "cruel and pitiless killer" and said he had "not had the courage" to come to court. Bellfield was reported to be the first person in Britain to receive two.
The second order added nothing in practical terms, since the first already meant he would die in prison. Its value was declaratory, and the law that followed shows why that counts for something. In May 2022 the Ministry of Justice confirmed that Bellfield, held at HMP Frankland in County Durham, had applied to marry a woman who visited him. The prisons minister, Victoria Atkins, ordered an immediate review and called the proposal "absolutely appalling". Under the law as it stood, a prisoner on a whole life order could apply to marry and a governor could refuse only on security grounds. In June 2023 the Ministry accepted that "under current laws there are no legal routes to block this marriage". The government’s answer was a statute. The ban on marriage and civil partnership for whole life prisoners came into force on August 2, 2024, under the Victims and Prisoners Act. Bellfield had by then withdrawn the marriage application and applied for a civil partnership, and that application was blocked when the new law took effect. The Lord Chancellor can still permit a ceremony in the most exceptional circumstances. "Victims should not be tormented," the Justice Secretary, Shabana Mahmood, said, by seeing people who commit the most depraved crimes enjoy such moments in life.
Joanna Dennehy was 30 when she pleaded guilty at the Old Bailey on November 18, 2013, before Mr. Justice Sweeney, to the murders of Lukasz Slaboszewski, John Chapman and Kevin Lee in Peterborough in March 2013, to the attempted murder of two men in Hereford on April 2, and to three related offenses. Her own lawyers had not expected the pleas. Sentence was postponed. Her case was held back while the courts considered whether whole life orders could survive the European Court’s ruling in Vinter, and she was sentenced on February 28, 2014, by Mr. Justice Spencer.
His reasoning is the clearest account in these cases of how a trial judge now arrives at the order. He applied paragraph 4 of Schedule 21 to the Criminal Justice Act 2003, which covers murders of exceptionally high seriousness, and relied on the Court of Appeal’s 2014 decision in McLoughlin. He ruled that each of the three murders involved a substantial degree of premeditation, and that the murder of Kevin Lee involved sexual and sadistic conduct, but said he would have imposed a whole life order even without the finding of premeditation. Among the aggravating features he listed were that she had carried knives, that she took advantage of Chapman’s vulnerability and that she went on to try to kill two more men. He rejected her claim that she was too drunk in Hereford to know what she was doing, and did not accept that she felt remorse for those attempts. In a letter to the judge she said she felt none for the murders and that to say otherwise "would be a lie". "The element of just punishment and retribution requires the imposition of a whole life order," he said.
She received life imprisonment with a whole life order for each murder, concurrent life terms for the two attempted murders and concurrent 12-year terms for the related offenses. Mr. Justice Spencer called her "a cruel, calculating, selfish and manipulative serial killer". She was only the third woman in Britain to receive a whole life term, after Myra Hindley and Rose West. Three men who had helped her were sentenced the same day; the judge gave the driver, Gary Stretch, a life sentence for the attempted murders with a minimum of 19 years, the ordinary kind of life sentence beside the extraordinary one. No appeal against her convictions or the order has been reported. In 2016 she brought a claim over her segregation in prison that was funded by legal aid, and on May 26, 2016, the High Court rejected her claim for damages for human rights violations. As of August 2023 news reports she was still serving the order.
Lucy Letby, a neonatal nurse at the Countess of Chester Hospital, was sentenced on August 21, 2023, by Mr. Justice Goss at Manchester Crown Court, in her absence, to life imprisonment with a whole life order on each of 14 counts. A jury had convicted her of murdering seven babies and attempting to murder six others between June 2015 and June 2016. It acquitted her on two counts of attempted murder and could not agree on six others. Only the count concerning one baby, Child K, was retried, and in July 2024 a second jury convicted her of attempted murder on it. On July 5, 2024, she received a fifteenth whole life order. The babies are known only by letter, under reporting orders.
The figure measures counts, not the order’s practical effect, which was complete after the first. What sets her case apart is that the orders sit beside a question of guilt that is still being argued in public. She has denied harming any baby. The Court of Appeal refused her permission to appeal in May 2024 and again in October 2024. Doctors and scientists working with her new legal team have since disputed the medical evidence on which she was convicted, and on February 13, 2026, the Criminal Cases Review Commission confirmed that a review of her convictions is under way. The Nursing and Midwifery Council struck her off its register on December 12, 2023. In January 2026 the Crown Prosecution Service decided not to charge her over further babies at the Countess of Chester and Liverpool Women’s Hospital, and the decision was upheld on review in August 2026. A statutory public inquiry under Lady Justice Thirlwall reported on September 15, 2026, on the hospital’s failure to act; it did not reexamine the convictions.
As of September 2026 her sentences stand, and the only routes to unsettling them run through the Commission and the Court of Appeal.
Steve Wright holds the sentence that shows the limits of the order. On February 21, 2008, a jury at Ipswich Crown Court, nine men and three women who had deliberated for two days, convicted him of murdering five women in Ipswich between late October and December 2006: Tania Nicol, Gemma Adams, Anneli Alderton, Annette Nicholls and Paula Clennell. The next day Mr. Justice Gross passed a life sentence with a whole life order, citing premeditation and planning. "It is right you should spend your whole life in prison," he told him. Wright lost his bid at the Court of Appeal on February 24, 2009, according to the Press Association’s chronology.
For 18 years he admitted nothing. He was arrested in prison in July 2021, arrested again in December 2023 and charged on May 22, 2024, with the kidnap and murder of 17-year-old Victoria Hall of Trimley St Mary, Suffolk, in September 1999, and the attempted kidnap of a 22-year-old woman the day before. In January 2026 Mr. Justice Bennathan ruled that the jury could be told of his five murder convictions. On February 2, 2026, the day his trial at the Old Bailey was due to open, he pleaded guilty to everything charged.
Sentencing him on February 6, 2026, the judge said that under the law that applies today he would have imposed a whole life order, given the murder of a child after an abduction, the suffering she endured, the planning, the attempted kidnap the night before and the murders that followed. But the crime dated from 1999 and he had to apply the regime in force then. Under that regime whole life terms were kept for a very small number of multiple killers, and in 1999 Wright had not yet become one. The older guidance pointed to a minimum just over 40 years, and the judge allowed a small reduction for the late plea. He imposed life with a minimum term of 40 years, with concurrent terms of 12 years for the kidnap and nine for the attempted kidnap. Given the sentence for his other crimes, he told Wright, it was almost certain he would die in prison. Wright was 67. Two sentences passed 18 years apart on one man therefore stand on different law: the 2008 order is a whole life order, and the 2026 term is a number that will, as a matter of arithmetic, outlast him.
David Fuller, a hospital electrician, murdered Wendy Knell, 25, and Caroline Pierce, 20, in Tunbridge Wells in 1987 and was not identified until 2020, when familial DNA work led police to a relative. He was arrested in Heathfield, East Sussex, on December 3, 2020. The judge treated both killings as premeditated and sexually motivated. Fuller admitted the murders partway through his trial at Maidstone Crown Court in November 2021, and on December 15, 2021, Mrs. Justice Cheema-Grubb imposed whole life orders for both, with a concurrent 12-year term for 51 further offenses, 44 of them concerning the dead in two hospital mortuaries. She told him he would spend the rest of his life in prison. In December 2022 he was sentenced to four more years, concurrent, for 16 further offenses, and the judge told him he would remain in prison until his death.
The case exposed an imbalance in the law elsewhere. When Fuller was sentenced, the offense of sexual penetration of a corpse under section 70 of the Sexual Offences Act 2003 carried a maximum of two years and did not cover touching without penetration. The independent inquiry under Sir Jonathan Michael recorded that many families thought the sentences too lenient, and the chair wrote to the Ministry of Justice asking that their experience be weighed in any sentencing review. The Crime and Policing Act 2026, enacted on April 29, 2026, replaced section 70 with a wider offense of sexual activity with a corpse, with a maximum of seven years for the most serious form and five otherwise. It came into force on September 29, 2026. In Fuller’s own case the maximum on those offenses never mattered to how long he will be held: the two whole life orders, set by the murders, governed that from the first.
Stephen Port, a chef from Barking in east London, was convicted at the Old Bailey on November 23, 2016, of the murders of Anthony Walgate, Gabriel Kovari, Daniel Whitworth and Jack Taylor between June 2014 and September 2015, and of 18 further offenses against other young men. Mr. Justice Openshaw sentenced him on November 25, 2016. The judge accepted that Port intended really serious harm rather than death, but ruled that he foresaw a high risk of death, especially after Walgate died. He listed the aggravating features: four murders, a persistent course of conduct against young men, planning, the removal of phones and planting of evidence, and two murders committed while Port was on bail. The absence of earlier convictions for violence, he said, "counts for little". The seriousness of the case was so exceptionally high that a whole life order was "justified; indeed it is required".
The case matters for two reasons. First, it shows that a finding of intent to cause serious harm, short of intent to kill, does not stand in the way of the order when the other features are present. Second, the sentencing remarks separate the question of the sentence from the question of police conduct: the judge said that whether the Metropolitan Police had acted correctly "is for others to decide". Others did. Fresh inquests in 2021 concluded that all four men had been unlawfully killed and that police failings probably contributed to the deaths of the last three, and in November 2023 the Independent Office for Police Conduct told eight current and former officers they faced gross misconduct investigations. Port began an application to appeal against the murder convictions in August 2018; no later appeal has been reported.
Stephen Griffiths was 40 when he pleaded guilty at Leeds Crown Court on December 21, 2010, to the murders of three Bradford women, Susan Rushworth, Shelley Armitage and Suzanne Blamires, and received life sentences with a whole life order on each count from Mr. Justice Openshaw. A psychology graduate who had been a part-time research student at the University of Bradford, he had given his name at his first court appearance as "the crossbow cannibal". The judge said he had no doubt that the crimes were so wicked and monstrous that Griffiths should spend the rest of his life in prison. He recorded that Griffiths had shown no remorse and had never apologized "in even the most perfunctory way". Sentencing followed pleas, not a trial, which is worth setting beside Letby: the order requires no contested jury at all. Police said at the time that they had no evidence linking him to any other killing. In November 2024 a report from prison sources said he was still serving the order.
Robert Black is the contrast. A delivery driver for a London poster firm, he was convicted in 1994 at Newcastle upon Tyne of the kidnapping and murder of three girls, Susan Maxwell, 11, Caroline Hogg, 5, and Sarah Harper, 10, and of a 1988 offense against a 15-year-old girl in Nottingham. In 2011, at Armagh Crown Court, a jury convicted him of the kidnapping and murder of Jennifer Cardy, 9. Arrested in Stow, in the Borders, on July 14, 1990, he had pleaded guilty at Selkirk Sheriff Court to an offense against a six-year-old girl. Four murders were later proved against him. Neither court gave him a whole life order.
In 1994 Mr. Justice Macpherson imposed life sentences, reported by the Yorkshire Post as ten in all, with a minimum term of 35 years, which the Northern Ireland judge later said would run to 2029. On December 8, 2011, Weatherup J imposed life for the murder with a minimum term of 25 years from October 27, 2011, and a discretionary life sentence for the kidnapping. The Court of Appeal in Northern Ireland dismissed his appeal on June 27, 2013, in R v Black [2013] NICA 35. Why each judge chose a number over a whole life order has not been made public. The minimum term of 35 years from 1994 would have kept Black in custody until he was about 82. He did not live that long. He died at HMP Maghaberry on January 12, 2016, aged 68, and an inquest jury returned a finding of cardiac arrest on December 7, 2018. Devon and Cornwall Police said in 2016 that he would in all probability have been charged over the 1978 case of Genette Tate, 13; he never was.
Set beside Letby’s 15 orders, Black’s two sentences show that the order is a choice made case by case. The number of dead does not decide it by itself.
Nine of these ten were told, in plain words, that the sentence is for life and the life will be spent in prison. What differs is who said it and when. Hindley’s number was chosen by successive Home Secretaries and defended in the House of Lords; Moore’s was a minister’s, then the High Court’s. Bellfield, Dennehy, Letby, Port, Griffiths and Wright in 2008 heard it from trial judges. Hindley lost every round in Britain. Moore lost in the British courts and then won the principle in Strasbourg without winning anything for himself. Wright’s second sentence shows the order cannot be applied to an offense that predates the rules that would have called for it. Fuller’s shows a whole life order for two murders sitting beside sentences for other crimes that were short by comparison, until Parliament changed the maximum. Letby’s shows the order standing while the evidence behind it is argued in the open. Black, who killed four girls and was given a number instead, stands as the case that a judge can decline.
• May 6, 1966: Hindley convicted at Chester Assizes; life sentences passed.
• November 30, 1983: Home Secretary Leon Brittan announces the tariff system to the House of Commons.
• March 1985: provisional 30-year tariff for Hindley, not communicated to her.
• 1990: Home Secretary David Waddington decides on a whole-life tariff for Hindley.
• November 29, 1996: Peter Moore convicted of four murders.
• February 3, 1997: Home Secretary Michael Howard confirms Hindley’s whole-life tariff.
• November 19, 1997: Home Secretary Jack Straw maintains it.
• December 18, 1997: Divisional Court dismisses Hindley’s application.
• November 5, 1998: Court of Appeal dismisses her appeal and gives leave to the House of Lords.
• March 30, 2000: House of Lords dismisses her appeal, five judges to nil.
• September 27, 2002: Secretary of State sets Moore’s whole-life tariff.
• November 2002: Hindley dies in custody; days later the House of Lords rules against ministerial tariff-setting.
• February 22, 2008: Steve Wright receives a whole life order for five murders.
• February 26, 2008: Bellfield receives his first whole life order.
• June 12, 2008: High Court makes a whole life order for Moore.
• February 26, 2009: Court of Appeal dismisses Moore’s appeal.
• June 24, 2011: Bellfield receives a second whole life order.
• January 17, 2012: Strasbourg Chamber rules against Moore, Vinter and Bamber by four votes to three.
• July 9, 2013: Grand Chamber rules, 16 to one, that their sentences breach Article 3.
• November 18, 2013: Dennehy pleads guilty.
• February 28, 2014: Dennehy receives a whole life order from Mr. Justice Spencer.
• November 25, 2016: Stephen Port sentenced to a whole life order.
• January 17, 2017: Grand Chamber judgment in Hutchinson v. the United Kingdom.
• December 15, 2021: David Fuller receives whole life orders for two murders.
• August 21, 2023: Letby receives 14 whole life orders; a fifteenth follows on July 5, 2024.
• August 2, 2024: marriage and civil partnership barred for whole life prisoners.
• February 6, 2026: Wright sentenced to life with a 40-year minimum for the 1999 murder.
• September 15, 2026: Thirlwall Inquiry reports.