R v Adam Daniel Froom [2026] EWCA Crim 805

“The report will also show that in my clinical opinion Mr Froom is a vulnerable gentleman based on his mental health history. He has also been a victim of physical violence in the past. In my clinical opinion the likely presence of ADHD is not as informative as a causal factor for his presentation than the presence of potential personality disorder, depression and dysregulated emotional control/impulse control problems. I would view any potential ADHD as an exacerbating factor to these other underlying conditions/traits." Later in his report he stated: 41. … in my clinical opinion, Mr Froom presents is more significantly informed by likely mental health conditions such as depression and personality disorder/impulse control disorder, than they are ADHD. I note that Mr Froom presents with dysregulated emotional control and impulsivity. He reports that he has turned to drugs and alcohol in the past. He has also resorted to self-harm to help regulate his emotions. Similarly, his outbursts of anger are likely to be a result of dysregulated emotional control. In my clinical opinion, these features of his behaviour are not significantly informed by ADHD but may be exacerbated by it… he is a vulnerable individual who is likely to be in need of specialist psychological support. Without intervention, I would have concerns over Mr Froom’s ability to contain his emotions and avoid further episodes of dysregulated emotional control/anger.”

"Mr Froom is not suffering from any mental disorder which is either of a nature or degree that warrants compulsory treatment within a psychiatric hospital under the provisions of the Mental Health Act 1983. There are no recommendations for a hospital order under section 37 of the Mental Health Act 1983. Mr Froom is being proscribed medications for attention deficit hyperactivity disorder. I recommend that Mr Froom continues to comply with the treatment for ADHD. I understand that he has asked for the mental health services to review the dosage of the medication. I would support the mental health services reviewing Mr Froom's mental state and titrating the medication appropriately. I recommend that Mr Froom remains completely abstinent from alcohol and substances. He is likely to benefit from interventions to manage his substance misuse. These interventions can be offered in the prison or in the community by the Criminal Justice Agency's health services or both. His likelihood of abstinence would increase if he were to be compelled by law to do so and required to comply with random testing for alcohol or drug use."

"In terms of punishment the courts have tried to deal with you creatively by passing orders obviously designed to address your offending. You have a history of breaching orders, not only by non-compliance but by committing further criminal offences and also, as here, by simply ignoring court orders and doing what you want. It is very clear that you are unable to control yourself or your temper. That much was clear at your first appearance in this court on this case when I refused you bail. You have been given opportunities to address your offending and have ignored them."

"If the foreseen specified offence is not serious, there will be comparatively few cases in which a risk of serious harm will properly be regarded as significant. The huge variety of offences in Schedule 15 includes many which, in themselves, are not suggestive of serious harm. Repetitive violent or sexual offending at a relatively low level without serious harm does not of itself give rise to a significant risk of serious harm in the future. There may, in such cases, be some risk of future victims being more adversely affected than past victims but this, of itself, does not give rise to significant risk of serious harm."