When Vikernes was convicted, it was possible to be released on parole after serving 12 years of a 21-year sentence, but in 2002, before he became eligible, the Norwegian Parliament had extended this to 14 years. In June 2006, after serving 12 years, Vikernes was denied parole by the Department of Criminal Justice for this reason. His lawyer, John Christian Elden, has complained that the policy change is a form of retroactive legislation. Article 97 of the Norwegian constitution forbids any law being given retroactive force. Vikernes was denied parole again in June 2008, although he was allowed to leave Tromsø Prison for short periods to visit his family. His full sentence would run for another seven years. In March 2009, however, his parole was announced. He had then served nearly 15 years of his 21-year sentence. On 22 May 2009, he confirmed that he had been released from prison on probation.