Test for recalling a life prisoner from parole
R v Parole Board, ex parte David Adam Watson (1996).
CA (Sir Thomas Bingham MR, Rose LJ and Roch LJ).
Summary: Recalling a life prisoner from parole although no criminal offence was actually proved against him nor any breach of any condition in his licence established.
Appeal against dismissal of a renewed application for judicial review of the Parole Board's decision to refuse to renew parole of a prisoner serving a discretionary life sentence for buggery and indecent assault passed in 1975. The offences were committed against schoolboys and were accompanied by beatings and other sadistic acts. At the time of those convictions the appellant had previous convictions of indecent assault on boys aged between nine and 13 and buggery of a boy aged nine.