Regina (Elam) v Secretary of State for Justice [2012] EWCA Civ 29; [2012] WLR (D) 14
“The licence expiry date applicable to a prisoner serving consecutive terms of imprisonment including at least one term of 12 months or more was to be determined by the provisions of section 264(3) of the Criminal Justice Act 2003 unless all the offences for which the sentences were imposed had been committed before section 264 came into force on 4 April 2005; in such a case, section 37(1) of the Criminal Justice Act 1991 continued to govern the licence expiry date by virtue of the saving provision in paragraph 19 of Schedule 2 to the Criminal Justice Act 2003 (Commencement No 8 and Transitional and Saving Provisions) Order 2005.”
WLR Daily, 27th January 2012
Source: www.iclr.co.uk
