R. v Lees-Wolfenden (Danielle Jayne) [2006] EWCA Crim 3068, [2007] 1 Cr. App. R. (S.) 119 should be read as meaning that “a supervision requirement” as defined by the Criminal Justice Act 2003 s.213 was not mandatory, although the period during which requirements ran was referred to in s.189(1A) of the 2003 Act as “the supervision period”. Section 189 merely required one or more of the requirements listed in s.190 to be incorporated into the order and, by virtue of s.190(1)(a), a requirement for supervision was just one of those.

[2012] EWCA Crim 2662