On Friday 2nd November Stephen Farrow was sentenced to a ‘whole life’ tariff after being convicted of the murders of two people (see here for more details of sentencing for murder). The sentencing remarks are not available, but it seems that these were motiveless killings. He had knocked a 77 year old woman unconscious before laying her out on a bed and stabbing her four times. Six weeks later he killed a vicar, stabbing him seven times, before leaving his body surrounded by various items, including an open bible, gay pornography and a condom wrapper.
It seems that Mr Farrow was psychopathic (but not ‘mentally ill’ in that he knew the ‘nature and quality’ of what he was doing). He had expressed strong views about the church and had told one of the psychiatrists who examined him that he was intending to crucify the vicar on the floor.
Mr Farrow had several previous convictions, some for violent offences (the most serious being an aggravated burglary where he attacked an old lady). He is also clearly a very dangerous man. Is it that of itself that caused the whole life tariff to be passed?
The short answer is no. The reason why there is a mandatory life sentence for murder is that it is assumed by Parliament that all murderers are dangerous and that the public require protection from them. This protection is given by the life sentence (see the case of GL  EWCA Crim 802 for confirmation of this).
In this case there were two murders. It seems that the reason that the murder fell into the higher category with a whole life tariff is that both of the murders involved ‘sadistic conduct’, namely the ritualistic nature of the killing and the infliction of stab wounds against an individual who had been rendered unconscious.
Is this correct? In the absence of the sentencing remarks it is hard to say. There is no definition of ‘sadistic conduct’, and it is clear that it is wider than just sexual sadism. On the face of it, however, it may be that the Judge was not correct to find that both of these murders qualified (it is clear that a tariff in excess of 30 years would have been amply justified and given that Mr Farrow is now 48 a, for example 35 year tariff, may practically have amounted to a whole life tariff). It will be necessary to wait for an appeal to see fuller facts before commenting.