R (Regina) v Secretary of State for the Home Department, Ex Parte H... [2001] 1 AC 410

In life sentences the Home Secretary can decide when to grant early release of life imprisonment offenders, making his decision based on a tariff system.

He initially decided that she could be released after 30 years, but after it became apparent that she had committed more crimes he upgraded this to the full life sentence.

She sought judicial review of this but HL dismissed her claim and held that the change in tariff was lawful because:

1. New crimes were uncovered and

2. The initial tariff had just been provisional and had not been communicated to her, and

3. That the term was not disproportionate given the crimes she had committed.