Since the abolition of the death penalty in the Netherlands in 1870, life imprisonment has almost always meant imprisonment until death. Though the prisoner can appeal for pardon, it must be granted by royal decree; since the 1970s, only two such pardons have been successful, both being terminally ill. Since 1945, 41 criminals (excluding war criminals) have been sentenced to life imprisonment. There has been a noticeable increase of life imprisonment sentences being given in the last decade, and more than triple the number of life imprisonment sentences in the last few years than the previous decades.
Due to the strict nature of the sentence, most "common" murders result in a sentence of around 12 to 30 years. The judicial panel (always composed of three members) is not able to award sentences of longer than 15 years' imprisonment for manslaughter alone (so not combined with other facts constituting an offence), so if malice aforethought has not been proven, a criminal will never receive a sentence of longer than 15 years. The only life sentence for a single murder without gravitating circumstances was given in 2005 to Mohammed Bouyeri for the murder of Dutch film directorTheo van Gogh, due to its strong political nature. In all other cases, there has been circumstances of recurrence (murder committed after sentencing for another murder), multitude (several murders) or severe gravity to the crime (i.e. torture murder).