activity, curfew, exclusion, residence and others, alone or in combination with each other. The intent was to tailor sentences more closely to the offender. Combined custody and community sentences The previously deprecated "suspended sentence of imprisonment" returns, also allowing elements of a community order (see above) to be imposed at the same time. This ensures the offender knows what sentence of imprisonment is facing him or her if he or she fails to comply with the order or commits a further offence during its suspended period. Provision is made for sentences of intermittent custody, and custodial sentences followed by period of community work and supervision. Dangerous offenders The Act replaced the previous law on the mandatory sentencing of defendants convicted of violent or sexual crimes, introducing compulsory life sentences or minimum sentences for over 150 offences (subject to the defendant meeting certain criteria). The Act created a new kind of life sentence, called "imprisonment for public protection" (or "detention for public protection" for those aged under 18), which may even be imposed for offences which would otherwise carry a maximum sentence of ten years. In response to unprecedented prison overcrowding, Parliament passed sections 13 to 17 of the Criminal Justice and Immigration Act 2008 (with effect from 14 July 2008), which imposed stricter criteria for the imposition of these sentences, and restored judicial discretion by providing that they were no longer compulsory when the criteria were met. Life sentences for murder The House of Lords ruled in R v Secretary of State for the Home Department ex parte Anderson that the Home Secretary was not permitted to set minimum terms for life sentences. The reasoning was on the basis that in order to have a fair trial under Article 6 of the European Convention on Human Rights a defendant should be sentenced by an independent tribunal (that is, a judge) and not a politician who will have extraneous and irrelevant concerns which may affect his or her judgment. The Home Secretary's (David Blunkett MP) response was outlined in a written response to a parliamentary question on 25 November 2002. Mr Blunkett said The case of Anderson deals with the Home Secretary's power to set the tariff, or minimum period a convicted murderer must remain in custody until he becomes eligible for release. This power has ensured ministerial accountability to Parliament within the criminal justice system for the punishment imposed for