On 2 May 2024, a judicial review brought by an OLR  (order for lifelong prisoner) against the Scottish Government was upheld by the Outer House, Court of Session. It ruled that the petitioner’s rights under under Article 5(1) of the European Convention on Human Rights had been breached as a result of a 20 month delay in the prisoner accessing the rehabilitative course required to demonstrate a reduced risk to the Parole Board.  His detention was ruled to have become arbitrary in an Article 5(1) sense, until real opportunities for rehabilitation were provided to him.