“Where a defendant was sentenced to a mandatory sentence of life imprisonment and the minimum term was to be determined pursuant to paragraphs 3 or 6 of Schedule 22 to the Criminal Justice Act 2003 (which related to transitional cases) a reduction in the length of the minimum term could take account of exceptional progress made by the defendant whilst in prison. However, possible reductions for exceptional progress in prison did not form part of any appeal process for sentences imposed after 18 December 2003.”
WLR Daily, 1st December 2011
Source: www.iclr.co.uk