THERE can be little doubt that there is disagreement between the Court of Appeal and the European Court of Human Rights (ECtHR) over the whole-life sentence in England and Wales. Despite evolving jurisprudence on the issue of life-long detention emanating from Strasbourg, the Court of Appeal has readily upheld the English whole-life sentence in recent years. It has been doing so by adopting a very wide interpretation of the Secretary of State's power to order the compassionate release of a life sentence prisoner.