Life imprisonment
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Life imprisonment (also known as a life sentence, lifelong incarceration or life incarceration) is a sentence of imprisonment for a serious crime under which the convicted person is to remain in jail for the rest of his or her life. Examples of crimes for which a person could receive this sentence include murder, severe child abuse, rape, high treason, severe or violent cases of drug dealing or human trafficking, or aggravated cases of burglary or robbery resulting in death or grievous bodily harm.
This sentence does not exist in all countries. Portugal was the first country in the world to abolish life imprisonment by the Prison reforms of Sampaio e Melo, in 1884. However, where life imprisonment is a possible sentence, there may also be formal mechanisms to request parole after a certain period of imprisonment. This means that a convict could be entitled to spend the rest of the sentence (that is, until he or she dies) outside of prison. Early release is usually conditional depending on past and future conduct, possibly with certain restrictions or obligations. In contrast, in jurisdictions without life imprisonment, a convict who has served the given prison sentence is free upon release.
The length of time and the modalities surrounding parole vary greatly for each jurisdiction. In some places convicts are entitled to apply for parole relatively early, in others only after several decades. However, the time of legally being entitled to apply for parole does not often tell anything about the actual date of being granted parole. Article 110 of the Rome Statute of the International Criminal Court stipulates that for the gravest forms of crimes (e.g., war crimes, crimes against humanity and genocide), a prisoner ought to serve two thirds of a fixed sentence, or 30 years in the case of life imprisonment. The highest determined prison sentence that can be imposed in the ICC is 40 years in prison, other than life imprisonment. After this period, the court shall then review the sentence to determine whether it should be reduced.
Unlike other areas of criminal law, sentences handed to minors do not differ from those given to legal adults. A few countries worldwide had allowed for minors to be given lifetime sentences that have no provision for eventual release. Countries that allow life imprisonment without the possibility of parole for juveniles include Antigua and Barbuda, Argentina, Australia, Belize, Brunei, Cuba, Dominica, Saint Vincent and the Grenadines, the Solomon Islands, Sri Lanka, and the United States. Of these, only the United States currently has minors serving such sentences.[1] As of 2009, Human Rights Watch had calculated that there were 2,589[2][3] youth offenders serving life without parole in the United States.[4]
In 2010, the United States Supreme court ruled that sentencing minors to life without parole for crimes other than first-degree murder violated the 8th Amendment's ban on "cruel and unusual" punishment, in the case of Graham v. Florida.[5]
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[edit] World view
Life imprisonment sentence is used
Life imprisonment may only be imposed under certain restrictions
Life imprisonment laws have been abolished
Life imprisonment status unknown, presumed legal
[edit] Reform or abolition
In a number of countries, life imprisonment has been effectively abolished. The majority of countries whose governments have abolished both life imprisonment and indefinite imprisonment have been culturally influenced or colonized by Spain or Portugal, and have written such prohibitions into the current constitutional law of these countries. The most populous nation-state to abolish all forms of life imprisonment is Brazil; Article 84, paragraph 19 of the Brazilian Constitution sets a mandatory cap on prison terms at 30 years (ironically, this same article of the constitution allows for capital punishment in cases of treason, defection, mutiny and genocide during wartime).
A number of European countries have abolished all forms of indefinite imprisonment, including Serbia, Croatia, Spain and Bosnia and Herzegovina which set the maximum sentence at 40 years and Portugal which sets the maximum sentence at 25 years; Norway has abolished life imprisonment, but retains other forms of indefinite imprisonment. The only country in Asia have abolished all forms of indefinite imprisonment is Nepal; the Chinese dependency (Special Administrative Region) and former Portuguese colony of Macau also maintains a mandatory cap on prison sentences, having inherited the law from Portuguese rule. One African country, the Republic of the Congo, is known to have instituted a 30 years mandatory cap on prison sentence terms.
In South and Central America, Honduras, Nicaragua, El Salvador, Costa Rica, Venezuela, Colombia, Uruguay, Bolivia, Ecuador, and the Dominican Republic have all abolished life imprisonment. The maximum sentence in Honduras is 40 years, 50 years in Costa Rica, 60 years in Colombia, 30 years in Nicaragua, El Salvador, Bolivia, Uruguay, and Venezuela, and 25 years in Ecuador.
In the United States, a 2009 report by the Sentencing Project suggested that life imprisonment without parole should be abolished, a suggestion that was met with opposition from law enforcement officials[6].
[edit] Overview by jurisdiction
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This section does not cite any references or sources. Please help improve this section by adding citations to reliable sources. Unsourced material may be challenged and removed. (September 2009) |
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This list is incomplete; you can help by expanding it.
[edit] Summary by country
| Jurisdiction (link to details) | Life imprisonment | Minimum to serve before eligibility for requesting parole | Maximum length of sentence (under life) | Indefinite sentence (excl. preventive or psychiatric detainment) | Mandatory sentence | Possible other sentence | Under age of 18 (or 21) | Pardon, amnesty, other release |
|---|---|---|---|---|---|---|---|---|
| Abkhazia | ?? | ?? | ?? | ?? | ?? | ?? | ?? | ?? |
| Afghanistan | Yes | 25 years or never | None | Yes | Murder, rape, robbery, sodomy | Treason, drug trafficking | Yes[citation needed] | By President |
| Argentina | Yes | 20 years, or never | None | Yes | Murder with aggravating circumstances; murder of a relative; murder of and/or by a police officer; treason | Serial rape | ?? | By president or governor of a state (depending on jurisdiction) |
| Austria[7] | Yes | 15 years | None | No | Genocide | Murder, leadership of a drug dealer gang, Nazi activism, production or distribution of chemical warfare agents to be used in armed conflict; abduction, robbery, rape and statutory rape if the crime causes the victim's death; sea and air piracy and arson if the crime causes the death of a large number of people | Maximum 20 years | Pardon by president |
| Australia | Yes | 10 years, 20 years, 25 years, or never; individually set by judge | None | Yes | Murder of police officer or other public official, murder in South Australia, Queensland, Northern Territory, aircraft hijacking. | Treason, terrorism, drug trafficking, rape, serious child sex offences | Must have minimum term set (under 18) | Compassionate release by Governor of state/Administrator of territory, or Governor-General |
| Azerbaijan | Yes | Never; usually pardon by President after 20–30 years | None | No | Murder, terrorism, war crimes, genocide | Drug trafficking, human trafficking, robbery, rape | Yes | By President |
| Belarus | Yes | 25 years | None | ?? | ?? | ?? | Maximum 15 years | ?? |
| Belgium | Yes | 10 years, or 16 years if recidivist[citation needed] | None | ?? | ?? | ?? | ?? | ?? |
| Belize | Yes | Never | ?? | ?? | ?? | ?? | ?? | ?? |
| Bolivia | No (Except in Wartime) | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Bosnia and Herzegovina | No | Varies, depending on sentence | 40 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Brazil | No (Except in Wartime) | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Bulgaria[8] | Yes | 20 years or never (depending on crime) | None | Yes | None | Aggravated murder, aggravated kidnapping, aggravated robbery, treason, espionage, war crimes, genocide, desertion in wartime | Maximum 12 years | By President |
| Canada | Yes | 7–25 years | None | Yes | High treason, murder, crimes against humanity | Drug trafficking, aggravated sexual assault, manslaughter, kidnapping, rioting, robbery, terrorism, war crimes | Yes, when tried as an adult | Compassionate release and pardon by minister of justice |
| Cape Verde | No | Varies, depending on sentence | 25 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Colombia | No | Varies, depending on sentence | 60 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Costa Rica | No | Varies, depending on sentence | 50 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Chile | Yes | 20 years, or never | None | Yes | Murder | ?? | ?? | By President |
| People's Republic of China | Yes | never | None | No | No | Various | Yes | By courts |
| Croatia | No[9] | Varies, depending on sentence | 40 years[9] | No | No life imprisonment sentence | No life imprisonment sentence | No life imprisonment sentence | No life imprisonment sentence |
| Cuba | Yes | Never; only pardon by president | None | No | Murder, Drug trafficking | ?? | Yes[citation needed] | By President |
| Cyprus | Yes | 20 years | None | ?? | ?? | ?? | ?? | ?? |
| Czech Republic[10] | Yes | 20 years | None | No | None | Some cases of murder, treason, terrorism, genocide, robbery, kidnapping, rape | No life imprisonment sentence | By President |
| Denmark | Yes | 12 years, or never[citation needed] | None[11] | Yes | ?? | ?? | Maximum 15 years | After 12 years entitled to request to Minister of Justice; granted by King or Queen of Denmark |
| Dominican Republic | No | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | 13-15 years (10 years) 16-17 years (15 years) | No life imprisonment sentence |
| Ecuador | No | Varies, depending on sentence | 25 years (35 years in exceptional cases) | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| El Salvador | No (Except in wartime) | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Egypt | Yes | Never | None | No | Murder, Rape, Kidnapping, Terrorism | Drug offenses | Yes | Pardon by president |
| Estonia | Yes | Never[12] | None | Yes (de facto) | ?? | ?? | Maximum length 10 years | Pardon by president[13] |
| Finland | Yes | 12 years for court release, any time for presidential pardon[14] | None | Yes | Murder, purposefully killing police officer | Genocide, high treason, espionage, war crimes, homicidal terrorist act | Maximum length 15 years (under age of 18); minimum 10 years for parole request (under age of 21) | By president, Helsinki Court of Appeal |
| France | Yes | 18–22 years, 30 years, or never | None | Yes, but only if decided by court at sentencing | None | Aggravated murder, aggravated torture, treason, terrorism, drug trafficking, crimes against humanity, war crimes, rape | Maximum length 20 years (under age of 16) | By president, with countersignature from Prime minister and ministry of justice |
| Germany | Yes | 15 years | None | Yes, but only if decided by court at sentencing | Murder, genocide, crimes against humanity, war crimes | See details | 10 years | By Federal President or Minister-President |
| Hungary | Yes | 20–40 years, or never | None | Yes | Murder, after 3 violent crimes | Genocide, high treason | No life imprisonment under 18; maximum length 15 years | By president |
| Honduras | No | Varies, depending on sentence | 40 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Hong Kong | Yes | Individually set by judge | None | Yes | Murder | ?? | Must have minimum term set | By Chief Executive of Hong Kong, under the recommendation of Long Term Prison Sentences Review Board |
| Iceland | Yes | 15 years | None | No | Murder, terorrism, drug and human trafficking, treason, torture | Violent cases of a felony, smuggling (excluding drugs and humans) | Maximum length 20 years in prison | By President |
| India | Yes | 25 years or never; individually set by judge | None | Yes | Murder, rape, robbery | Kidnapping | Yes | May be pardoned by President or have sentence commuted by Government |
| Indonesia | Yes | Never | None | Yes | Murder, terrorism, kidnapping, rape, treason | ?? | ?? | By President |
| Ireland | Yes | 12–30 years or never; individually set by judge | None | Yes[citation needed] | Murder, treason, some syringe injuries, etc. see details | See details | ?? | By President |
| Israel | Yes | 13–30 years, or never | None | Yes[citation needed] | Murder | Kidnapping child with intent to murder | No | By president |
| Italy | Yes | 21 years, 26 years, or never | None | Yes | Murder, terrorism, mafia association, drug trafficking, human trafficking, treason | Aggravated sexual assault, aggravated robbery, firearm trafficking | Maximum length 20 years imprisonment under 16 | By president |
| Jamaica | Yes | 10–30 years or never; individually set by judge | None | Yes | ?? | ?? | ?? | ?? |
| Japan | Yes | 10 years or never | None | No | Death sentence by instigation to a foreign aggression | ?? | Yes | By Emperor |
| Kazakhstan | Yes | Never | None | Yes | Murder, terrorism | ?? | Maximum 20 years | By President |
| Kiribati | Yes | 5–25 years, or never | None | ?? | ?? | ?? | ?? | ?? |
| Kosovo | ?? | ?? | ?? | ?? | ?? | ?? | ?? | |
| Laos | Yes | Never | None | Yes | ?? | ?? | ?? | ?? |
| Latvia | Yes | 20 years | None | ?? | ?? | ?? | ?? | ?? |
| Lebanon | Yes | Never | None | No | Murder, terrorism, treason | Drug trafficking and manufacturing | Yes | By President |
| Macau | No | Varies, depending on sentence | 25 years (30 in exceptional circumstances)[15] | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Malaysia | Yes | 20 years or never | None | Yes | Murder, drug offenses, serious firearms/ammunition/explosive offenses, terrorism, rape, sodomy, attack on monarch, violence to parliament, treason | ?? | ?? | By King / Monarch / Federal Pardon Committee |
| Mexico | No (exception of Chihuahua) | Varies, depending on sentence | 60 years | No[16] | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| The Netherlands | Yes | Never | None | Yes (de facto) | None | Attack on monarch, violence to parliament, several facts constituting an offence resulting into death of (a) person(s) (not manslaughter), manslaughter in combination with other facts, facts with intent to terrorism, treason | under 12: never prosecution 12–16: 10 year imprisonment max. 16–18: 20 years imprisonment max. |
By monarch (almost never granted) |
| Nepal | No | Varies, depending on sentence | 20 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| New Zealand | Yes | 10 years, 17 years, 20 years, or never; individually set by judge | None | Yes | Murder, treason | Manslaughter, certain drug related | Must have minimum term set (under 18) | Sentence may be reduced or pardon granted by the Governor General (Rarely done) |
| Nicaragua | No | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Nigeria | Yes | Never[17] | None | Yes | ?? | ?? | No life imprisonment sentence | ?? |
| North Korea | Yes | Never | None | Yes (de facto and de jure) | Murder, espionage, treason | ?? | Yes | By president |
| Northern Cyprus | Yes | Never; Only pardon by President | None | Yes | Murder, Drug trafficking, terrorism, treason | Espionage, war crimes, mutiny, desertion | Maximum sentence for murder is 24 years; only terrorism related cases | Pardon by president; requires counter signature from Prime Minister and Minister of Justice |
| Norway | No | Varies, depending on sentence | 30 years | Yes | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Pakistan | Yes | 25 years | None | ?? | ?? | ?? | ?? | By President |
| Panama | Yes | 25 years | None | Yes | Murder | ?? | Maximum 20 years | By President |
| Paraguay | No | Varies, depending on sentence | 25 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Peru | Yes | Never | None | Yes | Murder, terrorism | ?? | ?? | By President |
| Poland | Yes | 25 years or more—individually set by judge | None | No | None | Genocide, war crimes, high treason, murder, assassination attempt of Polish president | Maximum 25 years (under age of 18) | Pardon by president , Amnesty by act of parliament (last amnesty in 1989) |
| Portugal | No | Varies, depending on sentence | 25 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Romania | Yes | 20 years | None | ?? | ?? | ?? | ?? | ?? |
| Republic of the Congo | No | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Russia | Yes | 25 years | None | No | No | See details | 10 years for all persons under age 18 | By President |
| Saudi Arabia | Yes | Never | None | No | Possession of alcohol, apostasy, cross dressing | Homosexuality, Witchcraft, adultery, fornication | Yes | By King |
| Serbia | No | Varies, depending on sentence | 40 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Slovakia | Yes | 25 years | None | ?? | ?? | ?? | ?? | By President |
| Slovenia | Yes | 25 years | None | Yes | Murder, treason | ?? | ?? | By President |
| Somalia | Yes | Never | None | No | Murder, rape, robbery | Sodomy, adultery, crimes against humanity | Yes[citation needed] | By President |
| South Africa | Yes | 10, 15, or 25 years | None | No[citation needed] | Certain murder, rape and robbery | ?? | ?? | ?? |
| South Korea | Yes | 10 years or never | None | ?? | High treason, robbery (rape) with deadly outcomes, arson, murder of relative, etc. | ?? | Maximum 10 years (for certain violent crimes 20 years) | By President and requires agreement of National Assembly |
| South Ossetia | ?? | ?? | ?? | ?? | ?? | ?? | ?? | ?? |
| Spain | No | Varies, depending on sentence | 40 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Syria | Yes | Never | None | No | Murder, political crimes, terrorism, treason | Drug offenses | Yes | By President |
| Sweden | Yes | 10 years or never | None | Yes | None | Murder, kidnapping, arson, war crimes, espionage, sabotage, violent robbery | Life imprisonment sentence from 21 years | By the District Court of Örebro. |
| Switzerland | Yes | 10 years or 15 years; individually set by judge | None | Yes | None | Aggravated murder,[18] aggravated hostage-taking,[19] genocide,[20] endangering the independence of the country[21] | Maximum 4 years if aged 15–17 years (under 15 years, no imprisonment)[22] | By Federal Assembly (Parliament)[23] |
| Republic of China (Taiwan) | Yes | 25 years 10–20 years before June 30, 2006 |
None | Third violent crime | Aggravated murder, hard drug trafficking | Many violent crimes causing death, etc. | Banned by Criminal Code | By President |
| Tajikistan | Yes | Never | None | No | Murder, terrorism | Treason | Yes | By President |
| Turkey | Yes | Never; only pardon by the Presdient | None | Yes | Murder, drug trafficking, terrorism, treason | Military offenses, espionage, piracy | Life imprisonment for juveniles is commuted to sentences of up to 24 years | By President in case of permanent illness, disability or decrepitude |
| Turkmenistan | Yes | Never | None | No | Murder, terrorism | Treason | Yes | By President |
| UK: England and Wales | Yes | 15–40 years or never; individually set by judge | None | Yes | Murder | All common law offences, rape, inflicting GBH with intent, wounding with intent, treason, aggravated burglary, criminal Damage with intent to endanger life | No whole life tariff (under age of 21) | Compassionate release and pardon by minister of justice; amnesty by royal decree alone or with act of parliament (last amnesty in 1747). |
| UK: Scotland | Yes | 15–35 years or never; individually set by judge | None | Yes | Murder | ?? | No whole life tariff | Compassionate release by Cabinet Secretary for Justice (Scottish Government); amnesty by royal decree alone or with act of parliament |
| UK: Northern Ireland | Yes | 15–35 years; individually set by judge | None | No[24][25] | Murder | ?? | ?? | General release through a referendum based agreement in 1998 (became applicable in 3 cases i, ii, iii) |
| Ukraine | Yes | 25 years | ?? | No | Murder with aggravating circumstances | ?? | Maximum 15 yers | By President |
| United States | Yes | 15–35 years, or never (depending on crime) | None | Yes | Varies by state | Varies by state | Life without parole is not allowed for offenders under 18 except in cases of murder. The felony murder rule applies. [26] | By president or governor of a state (depending on jurisdiction) |
| Uruguay | No | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Uzbekistan | Yes | Never | None | No | Murder, terrorism | Treason | Maximum 10 years | By President |
| Vatican City | Yes | Never | None | No | Assassination of the pope, attempted assassination of the pope, terrorism, treason, murder | Drug trafficking, human trafficking, firearm trafficking | Yes in certain cases | By Pope |
| Venezuela | No | Varies, depending on sentence | 30 years | No | No life imprisonment sentence | No life imprisonment sentence | ?? | No life imprisonment sentence |
| Vietnam | Yes | Never | None | Yes (de jure) | ?? | ?? | Under 18: maximum 18 years imprisonment, under 16: maximum 14 years imprisonment jail | Usually amnesty after 20–30 years[citation needed] |
[edit] See also
[edit] Notes
- ^ The University of San Francisco Law School’s Center for Law & Global Justice has found no cases outside of the United States in which the sentence is actually imposed on juveniles.
- ^ "State Distribution of Youth Offenders Serving Juvenile Life Without Parole (JLWOP) | Human Rights Watch". Hrw.org. 2009-10-02. http://www.hrw.org/en/news/2009/10/02/state-distribution-juvenile-offenders-serving-juvenile-life-without-parole. Retrieved 2011-08-03.
- ^ "Stats by State « The Campaign for the Fair Sentencing of Youth". Endjlwop.org. http://www.endjlwop.org/the-issue/stats-by-state/. Retrieved 2011-08-03.
- ^ "The Rest of Their Lives: Life without Parole for Child Offenders in the United States", 2008.
- ^ "Graham v. Florida, 130 S. Ct. 2011 (2010).
- ^ Kevin Johnson (7/22/2009 11:19 PM). "Report wants life without parole abolished". USA Today. http://www.usatoday.com/news/washington/2009-07-22-lifers_N.htm.
- ^ section 18 of the Austrian criminal code
- ^ Criminal code of the Republic of Bulgaria
- ^ a b Kovčo Vukadin, Irma; Žakman-Ban, Vladimira; Jandrić-Nišević, Anita (2010). "Prisoner Rehabilitation in Croatia" (PDF). Varstvoslovje, Journal of Criminal Justice and Security 12 (2): 143–162. ISSN 1580-0253. http://www.fvv.uni-mb.si/varstvoslovje/articles/VS-2010-2-Croatia.pdf. Retrieved 1 December 2010.
- ^ Czech Criminal Code
- ^ nyhederne-dyn.tv2.dk/article.php/id-27931364
- ^ "Comparative Criminology | Europe - Estonia". Rohan.sdsu.edu. http://www-rohan.sdsu.edu/faculty/rwinslow/europe/estonia.html. Retrieved 2011-08-03.
- ^ "Estonia releases first life prisoner - BONJOUR L'ESTONIE". Shaan.typepad.com. 2008-11-06. http://shaan.typepad.com/shaanou/2008/11/estonia-release.html. Retrieved 2011-08-03.
- ^ "Oikeuslaitos - Imprisonment and community service". Oikeus.fi. http://www.oikeus.fi/16073.htm. Retrieved 2011-08-03.
- ^ "Código Penal - Art. 1 a 100" (in Portuguese). Imprensa Oficial (Government Printing Bureau). 14 November 1995. http://bo.io.gov.mo/bo/i/95/46/codpenpt/codpen0001.asp#1. Retrieved 2009-02-17.
- ^ For details of new rulings from Mexican Supreme Court, see: "Wanted Fugitive Raul Gomez Garcia Extradited to the U.S." (US Embassy in Mexico)[dead link] and Mexico alters extradition rules (BBC News))
- ^ Name (required) (2008-11-19). "6 NIGERIAN SOLDIERS BAG LIFE IMPRISONMENT « connectafrica". Connectafrica.wordpress.com. http://connectafrica.wordpress.com/2008/11/19/6-nigerian-soldiers-bag-life-imprisonment. Retrieved 2011-08-03.
- ^ art. 112 Swiss Criminal Code
- ^ art. 185 Swiss Criminal Code
- ^ art. 264 Swiss Criminal Code
- ^ art. 266 Swiss Criminal Code
- ^ (French)art. 25 Juvenile Criminal Code
- ^ art. 173 al. 1 let. k Constitution of the Swiss Confederation
- ^ Belfast Telegraph Fury over ruling that could see Attracta’s killer freed Saturday, 28 June 2008
- ^ Neutral Citation No.[2008] NICA 27 http://www.courtsni.gov.uk/NR/rdonlyres/D4920842-6C93-4664-8B52-641C305CCF6A/0/j_j_KER7217Final.htm
- ^ "Supreme Court restricts life sentences without parole for juveniles - Los Angeles Times". Latimes.com. 2010-05-17. http://www.latimes.com/news/nationworld/nation/la-na-court-juveniles-20100518,0,276108.story. Retrieved 2011-08-03.
