Alinea 34 Gerechtshof Den Haag 11 oktober 2016

Murray: “99. (…) It further observed in that case that the comparative and international law materials before it showed clear support for the institution of a dedicated mechanism guaranteeing a review no later than twenty-five years after the imposition of a life sentence, with further periodic reviews thereafter. (…) 102. The Court observes that the principle of rehabilitation, that is, the reintegration into society of a convicted person, (….) 103. Notwithstanding the fact that the Convention does not guarantee, as such, a right to rehabilitation, the Court's case-law thus presupposes that convicted persons, including life prisoners, should be allowed to rehabilitate themselves . (…) It has also held, with reference to Vinter and Others, that national authorities must give life prisoners a real opportunity to rehabilitate themselves (see Harakchiev and Tolumov, cited above, § 264). It follows from this that a life prisoner must be realistically enabled, to the extent possible within the constraints of the prison context, to make such progress towards rehabilitation that it offers him or her the hope of one day being eligible for parole or conditional release. This could be achieved, for example, by setting up and periodically reviewing an individualised programme that will encourage the sentenced prisoner to develop himself or herself to be able to lead a responsible and crime-free life.(…)”

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