Secretary of State for Justice v Glyn Razzell [2026] EWHC 2172 (Admin)

[2026] EWHC 2172 (Admin)Case No AC-2026-LON-002538
IN THE HIGH COURT OF JUSTICE
KING’S BENCH DIVISION
REFERRAL OF A RELEASE DECISION PURSUANT TO S.32ZAA OF THE CRIME (SENTENCES) ACT 1997
Venue Royal Courts of Justice, Strand, London, WC2A 2LLDate 14 August 2026
Before
MRS JUSTICE CHEEMA-GRUBB DBE
Between
SECRETARY OF STATE FOR JUSTICEClaimantGLYN RAZZELLDefendant
Mr Tristan Jones KC (instructed by The Government Legal Department) for ClaimantMr Matthew Stanbury (instructed by Reece Thomas Watson Solicitors) for DefendantHearing Hearing dates: 10 & 11 August 2026
JUDGMENTThis judgement was handed down remotely at 10.30am on 14 August 2026 by circulation to the parties by email and by release to the National Archives
[1]This is the first substantive hearing in which the Secretary of State for Justice (“SSJ”) has exercised his powers under s.32ZAA (2) Crime (Sentences) Act 1997, to direct the Parole Board to refer a decision that a prisoner should be released, to the High Court for review by a judge. The court must decide for itself whether it is no longer necessary for the protection of the public that Glyn Razzell (“GR” or “defendant”) be confined; if satisfied, it must order the Secretary of State to give effect to the release, and if not, it must quash the Parole Board’s decision.[2]The codified release test requires the decision maker not to be satisfied unless it considers there is “no more than a minimal risk” that, if no longer confined, the prisoner would commit a further offence causing serious harm, with mandatory regard to statutory risk factors and victim protection.[3]Glyn Razzell was convicted of murdering his wife Linda (her family expressed a wish for her to be referred to in this way) in March 2002 and on 14 November 2003 he was sentenced to life imprisonment. He was then aged 44 years and had previously been acquitted of violence towards her. The tariff was set in 2008 at 16 years (less time served on remand.) He has been a compliant prisoner. On 8 November 2017 he was transferred to open (Category D) conditions at HMP Hollesley Bay. He is now 66 years old. He has employment outside the prison and a flat. He has financial security from a pension. He maintains his innocence of the murder and refuses to identify a deposition site for his wife’s remains. Following completion of the tariff term on 12 September 2019 he applied for parole and had three previous parole hearings before the Parole Board met at a video-link hearing on 19 and 29 January 2026. The Panel consisted of an independent member, a psychologist and a retired Crown Court judge His Honour Patrick Thomas KC. In addition to a dossier of 1187 pages the panel received oral evidence from two psychologists, a Prison Offender Manager (“POM”), a Community Offender Manager (“COM”) and the defendant, who represented himself. Describing this as “a highly complex and demanding case”, the Board directed GR’s release on 12 April 2026.[4]In this referral the determinative question is likely to be whether, not-withstanding the defendant’s denial, non-disclosure of the victim’s body, lack of offence-focused risk reduction work, unresolved insight/triggers, and the dependence of the proposed risk-management plan on honesty and disclosure, the court can be satisfied affirmatively that the risk of serious harm he poses is no more than minimal. The Statutory and Procedural Framework[5]For post-tariff life prisoners s.28(5)-(6) Crime (Sentences) Act 1997 (“the 1997 Act”) provides that the Secretary of State must release on licence once the Parole Board directs release, but the Board must not direct release unless satisfied that it is no longer necessary for public protection that the prisoner remain confined. Section 28ZA codifies the public protection decision: the decision maker must consider whether there is no more than minimal risk of the prisoner committing a further offence causing serious harm, and “28ZA Public protection decisions (4) In making that assessment, the decision-maker must consider the risk that the prisoner would engage in conduct which would (or, if carried out in any particular part of the United Kingdom, would) constitute an offence specified in Schedule 18B to the Criminal Justice Act 2003. (5) When making a public protection decision about a prisoner, the following matters must be taken into account by the decision-maker—(a) the nature and seriousness of the offence in respect of which the relevant sentence was imposed;(b) the nature and seriousness of any other offence for which the prisoner has at any time been convicted;(c) the conduct of the prisoner while serving the relevant sentence (whether in prison or on licence);(d) the risk that the prisoner would commit a further offence (whether or not specified in Schedule 18B to the Criminal Justice Act 2003) if no longer confined;(e) the risk that, if released on licence, the prisoner would fail to comply with one or more licence conditions;(f) any evidence of the effectiveness in reducing the risk the prisoner poses to the public of any treatment, education or training the prisoner has received or participated in while serving the relevant sentence;(g) any submissions made by or on behalf of the prisoner or the Secretary of State (whether or not on a matter mentioned in paragraphs (a) to (f)). (6) When making a public protection decision about a prisoner, the decision-maker must in particular have regard to the protection of any victim of the prisoner. (7) For the purposes of subsection (6), a “victim” of a prisoner is a person who meets the definition of victim in section 1 of the Victims and Prisoners Act 2024 by reference to the conduct which constituted the offence for which the relevant sentence was imposed. (4) In making that assessment, the decision-maker must consider the risk that the prisoner would engage in conduct which would (or, if carried out in any particular part of the United Kingdom, would) constitute an offence specified in Schedule 18B to the Criminal Justice Act 2003. (5) When making a public protection decision about a prisoner, the following matters must be taken into account by the decision-maker— (a) the nature and seriousness of the offence in respect of which the relevant sentence was imposed; (b) the nature and seriousness of any other offence for which the prisoner has at any time been convicted; (c) the conduct of the prisoner while serving the relevant sentence (whether in prison or on licence); (d) the risk that the prisoner would commit a further offence (whether or not specified in Schedule 18B to the Criminal Justice Act 2003) if no longer confined; (e) the risk that, if released on licence, the prisoner would fail to comply with one or more licence conditions; (f) any evidence of the effectiveness in reducing the risk the prisoner poses to the public of any treatment, education or training the prisoner has received or participated in while serving the relevant sentence; (g) any submissions made by or on behalf of the prisoner or the Secretary of State (whether or not on a matter mentioned in paragraphs (a) to (f)). (6) When making a public protection decision about a prisoner, the decision-maker must in particular have regard to the protection of any victim of the prisoner. (7) For the purposes of subsection (6), a “victim” of a prisoner is a person who meets the definition of victim in section 1 of the Victims and Prisoners Act 2024 by reference to the conduct which constituted the offence for which the relevant sentence was imposed.[6]The definition referred to in ss. (7) is “1. Meaning of “victim”(1) In this Part, “victim” means a person who has suffered harm as a direct result of— (a)being subjected to criminal conduct, or (b)one or more of the circumstances mentioned in subsection (2).(2) The circumstances are— (a)where the person has seen, heard, or otherwise directly experienced the effects of, criminal conduct at the time the conduct occurred; (b)where the person’s birth was the direct result of criminal conduct; (c)where the death of a close family member of the person was the direct result of criminal conduct; (d)where the person is a child who is a victim of domestic abuse which constitutes criminal conduct.(3) The reference in subsection (2)(d) to a child who is a victim of domestic abuse is to be read in accordance with Part 1 of the Domestic Abuse Act 2021.(4) For the purposes of this Part— (a) “harm” includes physical, mental or emotional harm and economic loss; (b) “criminal conduct” means conduct which constitutes an offence.(5) It is immaterial for the purposes of subsection (4)(b) that— (a)no person has reported the offence; (b) no person has been charged with or convicted of the offence.” (1) In this Part, “victim” means a person who has suffered harm as a direct result of— (a)being subjected to criminal conduct, or (b)one or more of the circumstances mentioned in subsection (2). (a)where the person has seen, heard, or otherwise directly experienced the effects of, criminal conduct at the time the conduct occurred; (b)where the person’s birth was the direct result of criminal conduct; (c)where the death of a close family member of the person was the direct result of criminal conduct; (d)where the person is a child who is a victim of domestic abuse which constitutes criminal conduct. (3) The reference in subsection (2)(d) to a child who is a victim of domestic abuse is to be read in accordance with Part 1 of the Domestic Abuse Act 2021. (a) “harm” includes physical, mental or emotional harm and economic loss; (b) “criminal conduct” means conduct which constitutes an offence. (a)no person has reported the offence; (b) no person has been charged with or convicted of the offence.”[7]A recent addition to the list in s.28ZA is Helen’s Law, s.28A of the 1997 Act, which applies where a life sentence was imposed for murder or manslaughter, the victim’s remains are not known, and the Board believes that the prisoner has undisclosed information about where or how the remains were disposed of: the non-disclosure and the reasons for it must be taken into account. “s.28A Murder or manslaughter: prisoner's non-disclosure of information(1) The Parole Board must comply with this section when making a public protection decision about a life prisoner if— (a) the prisoner's life sentence was passed for murder or manslaughter; (b) the Parole Board does not know where and how the victim's remains were disposed of; and (c) the Parole Board believes that the prisoner has information about where, or how, the victim's remains were disposed of (whether the information relates to the actions of the prisoner or any other individual) which the prisoner has not disclosed to the Parole Board (“the prisoner's non-disclosure”).(2) When making the public protection decision about the life prisoner, the Parole Board must take into account— (a) the prisoner's non-disclosure; and (b) the reasons, in the Parole Board's view, for the prisoner's non- disclosure.(3) This section does not limit the matters which the Parole Board must or may take into account when making a public protection decision. The Parole Board accepted in this case that Helen’s Law applied but recognised that neither denial of the offence, nor Helen’s Law blocks release if the release criteria are otherwise met. (1) The Parole Board must comply with this section when making a public protection decision about a life prisoner if— (a) the prisoner's life sentence was passed for murder or manslaughter; (b) the Parole Board does not know where and how the victim's remains were disposed of; and (c) the Parole Board believes that the prisoner has information about where, or how, the victim's remains were disposed of (whether the information relates to the actions of the prisoner or any other individual) which the prisoner has not disclosed to the Parole Board (“the prisoner's non-disclosure”). (2) When making the public protection decision about the life prisoner, the Parole Board must take into account— (a) the prisoner's non-disclosure; and (b) the reasons, in the Parole Board's view, for the prisoner's non- disclosure. (3) This section does not limit the matters which the Parole Board must or may take into account when making a public protection decision.[8]Maintaining innocence of an offence will be relevant to the public protection decision. As Lord Bingham CJ recognised in R v The Parole Board, ex parte Oyston [2000] EWCA3552 (“Oyston”) at [43]. “Convicted prisoners who persistently deny commission of the offence or offences of which they have been convicted present the Parole Board with potentially very difficult decisions. Such prisoners will probably not express contrition or remorse or sympathy for any victim. They will probably not engage in programmes designed to address the causes of their offending behaviour. Since they do not admit having offended, they will only undertake not to do in the future what they do not accept having done in the past. Where there is no admission of guilt, it may be feared that a prisoner will lack any motivation to obey the law in future. Even in such cases, however, the task of the Parole Board is the same as in any other case: to assess the risk that the particular prisoner if released on parole, will offend again. In making this assessment the Parole Board must assume the correctness of any conviction. It can give no credence to the prisoner's denial. Such denial will always be a factor and may be a very significant factor in the Board's assessment of risk, but it will only be one factor and must be considered in the light of all other relevant factors. In almost any case the Board would be quite wrong to treat the prisoner's denial as irrelevant, but also quite wrong to treat a prisoner's denial as necessarily conclusive against the grant of parole.”[9]In the same case, Pil LJ, at [14], cited with approval Laws J summary of the jurisprudence, in R v Secretary of State for the Home Department, ex p Hepworth (unreported, 26 March 1997):
“(1) The Parole Board must assume the prisoner's guilt of the offence or offences of which he has been convicted. (2) The Board's first duty is to assess the risk to the public that the prisoner might commit further offences if he is paroled. (3) It is therefore unlawful for the Board to deny a recommendation for parole on the ground only that the prisoner continues to deny his guilt. (4) But in some cases, particularly cases of serious persistent violent or sexual crime, a continued denial of guilt will almost inevitably mean that the risk posed by the prisoner to the public or a section of the public if he is paroled either remains high or, at least, cannot be objectively assessed. In such cases the Board is entitled (perhaps obliged) to deny a recommendation.”
[10]A mechanistic approach is deprecated. The decision maker must not [45] “fall into the trap of treating the applicant’s denial as all but conclusive.” In Oyston itself, the offender (who had no other convictions but led a promiscuous lifestyle) continued to deny raping and indecently assaulting a 16-year-old girl he had met on an evening out, (the issue at trial was consent) but by the end of his six-year sentence he had applied for appropriate courses in custody, acknowledging and addressing his previous sexual behaviour and demonstrated an intention to modify his way of life. The balance of opinion was that he presented either no risk or only a low risk to the public. The court held that while the positive features might or might not be judged to outweigh the negative effect of his denial and other factors indicative of future risk, (and that was not a matter for the court to determine in the appeal) [44.] “...it would engage the attention of the court if the prisoner’s denial were treated as an all but conclusive indication of the risk of future offending.”[11]Another category relevant to the public protection assessment are credible allegations against the offender which have not resulted in criminal convictions. In R. (on the application of Pearce) v. The Parole Board of England and Wales [2023] AC 807at [87] (“Pearce”) the Supreme Court rejected a binary approach of “fact or non-fact” and held that there are three routes by which unproven allegations may influence the decision. In summary, the Board should attempt to investigate the facts to determine the truthfulness of the allegation(s). Alternatively, if no finding as to the truth can be made the Board should investigate to make findings as to the surrounding circumstances. Finally, if it is not possible to obtain sufficiently reliable evidence or to fairly resolve the truth of an allegation in respect of which the Board considers there to be a serious possibility that it is true, the Board may take the allegation into account and give it such weight as it thinks appropriate in a holistic assessment of all the information before it. The purpose is to enable the Board to make comprehensive and effective assessments of the risk that the release of the offender poses to the public. Following Pearce the Parole Board updated relevant Guidance on Allegations v2.0 (2023). Where there has been a previous trial and acquittal the guidance provides:
“8.8 The mere fact of an acquittal or no further action taken in relation to a charge does not preclude a panel from making a finding of fact that the allegation (or parts of it) underlying that charge was/were true, applying the balance of probabilities. However, panels should be cautious before doing so given that the safeguards ensuring fairness in court proceedings are not necessarily available during parole reviews. 8.9 The panel must also be cautious not to suggest that any criminal charge is true (please see paragraph 2.12). Accordingly, the panel cannot go behind any finding of not guilty to suggest that a prisoner has committed the crime they have been found not guilty of. 8.10 Panels may make findings of fact regarding the constituent aspects of an allegation that has resulted in an acquittal (…). 8.11 A finding of fact against the prisoner about an allegation of conduct underlying a charge will not equate to a finding of guilt or a criminal conviction – such a finding is the prerogative of the criminal courts applying a higher standard of proof […]. Nonetheless, such a finding may be taken into account by the panel when assessing risk.”
[12]The cross-reference in paragraph 8.9 above, to paragraph 2.12, is:
“2.12 Accordingly, while findings of guilt are not within the remit of the Parole Board, it may be that a panel finds as fact (on a balance of probabilities) that constituent elements of an offence have occurred. For example, a panel may find that it is more likely than not that the prisoner hit a person, but it is not within the panel’s remit to find the prisoner guilty of assault.”
[13]None of the previous three Boards assessed the unproven allegations in GR’s case in this structured way, although the alleged history of intimate partner violence (“IPV”) was well-documented in the psychology files and referred to at the hearings. In January 2026, the Board followed its guidance and dealt with the unproven allegations in a stand-alone section of the hearing on the first day.[14]The Parole Board is a statutory body, in being since 1967 and presently established under s.239 Criminal Justice Act 2003. It has responsibility for making decisions about release, whether that is before the end of a sentence, after recall or after the expiry of a minimum term of a life sentence. The Board acts judicially, as a body independent of the executive and is properly treated as a court for the purposes of the European Convention for the Protection of Human Rights and Fundamental Freedoms. The statutory test in s.28 of the 1997 Act is the test for all offenders whose release comes within the Board’s purview. The referral power to the High Court is separate from reconsideration or set-aside. Section 32ZAA of the 1997 Act applies to top-tier cases, including murder. It provides (as relevant): “32ZAA Referral of release decisions to High Court(1) This section applies where— (a) a prisoner is serving a life sentence imposed in respect of an offence specified or described in section 32ZAB, and (b) the Parole Board directs the prisoner’s release under section 28(5) or 32(5).(2) The Secretary of State may direct the Parole Board to refer the prisoner’s case to the High Court if the Secretary of State considers that— (a) the release of the prisoner would be likely to undermine public confidence in the parole system, and (b) if the case were referred, the High Court might not be satisfied that it is no longer necessary for the protection of the public that the prisoner should be confined (see section 32ZAC (1))”. (a) a prisoner is serving a life sentence imposed in respect of an offence specified or described in section 32ZAB, and (b) the Parole Board directs the prisoner’s release under section 28(5) or 32(5). (2) The Secretary of State may direct the Parole Board to refer the prisoner’s case to the High Court if the Secretary of State considers that— (a) the release of the prisoner would be likely to undermine public confidence in the parole system, and (b) if the case were referred, the High Court might not be satisfied that it is no longer necessary for the protection of the public that the prisoner should be confined (see section 32ZAC (1))”.[15]The SSJ has published policy guidance, Applicability of the Secretary of State Referral Power. This policy describes what features and characteristics would meet the public confidence limb in s.32ZAA(2)(a) and indicate that ‘a second look’ at a release decision may be necessary. In respect of murder convictions, the policy identifies exceptional cases that do not fall into a list of specified features (of which a case need meet only one listed feature). Here, the claimant finds exceptionality in the defendant’s on-going failure to reveal the whereabouts of Linda’s body, his lack of engagement with risk reduction work and the presence of relevant unproven allegations of violence against his wife prior to her murder.[16]The second limb of the statutory test ss.(2)(b) is a high bar, reflecting that the power is not intended to be regularly used. Specifically, the policy states at [15] that it is not to be used to respond to notoriety, media coverage, the public profile of an offender, or views or representations about the offender by victims. It is only to be invoked when there is evidence that the release test may not have been met. In this respect the policy provides at [14]; “In order to refer a case, the Secretary of State must have reason to believe that the Parole Board has reached the ‘wrong’ conclusion on the risk of a prisoner, to the extent that the release test is not met. To meet the second limb, there must be sufficient objective evidence of the Secretary of State finding a difference of view on the prisoner’s risk which could lead to a different conclusion on the release test, indicated or supported by a number of features of the decision. The Secretary of State will look at the whole bundle of evidence and the Parole Board’s release decision, taking into account things such as the assessed risk of harm of the prisoner, the arguments made on risk reduction and the sufficiency of the risk management plan.”[17]Section 32ZAC of the 1997 Act sets out the High Court’s functions in respect of the referral. It provides (as relevant): “32ZAC Powers of the High Court(1) On a referral of a prisoner’s case under section 32ZAA, and unless subsection (2B) applies on the referral, the High Court— (a) must, if satisfied that it is no longer necessary for the protection of the public that the prisoner should be confined, make an order requiring the Secretary of State to give effect to the Parole Board’s direction to release the prisoner on licence; (b) otherwise, must make an order quashing the Parole Board’s direction to release the prisoner on licence.(2) An order under subsection (1)(a) may include directions as to the conditions to be included in the prisoner’s licence on release …(3) An order under subsection (1)(b) […] has effect as if the prisoner’s case were disposed of by the Parole Board on the date on which the order was made”. (1) On a referral of a prisoner’s case under section 32ZAA, and unless subsection (2B) applies on the referral, the High Court— (a) must, if satisfied that it is no longer necessary for the protection of the public that the prisoner should be confined, make an order requiring the Secretary of State to give effect to the Parole Board’s direction to release the prisoner on licence; (b) otherwise, must make an order quashing the Parole Board’s direction to release the prisoner on licence. (2) An order under subsection (1)(a) may include directions as to the conditions to be included in the prisoner’s licence on release … (3) An order under subsection (1)(b) […] has effect as if the prisoner’s case were disposed of by the Parole Board on the date on which the order was made”.[18]Procedurally, CPR Part 77 applies a modified Part 8 process: the referral is treated as the Secretary of State’s application; the SSJ is claimant; the prisoner is defendant; the Parole Board and victims are not parties; and the claimant must file the reasons for referral, the Board’s decision, all material considered by the Board, and any further relevant material. It follows that this is not an appeal from the Parole Board, and it is not a judicial review of the Parole Board's reasoning. However, the evidence available for this review includes a transcript of the Parole Board hearing at which the defendant gave evidence. The nature of the proceedings, which concern the liberty of the subject, require all due expedition. By r77.25 the court may consider the application and determine it without a hearing or direct a hearing.[19]The Part 8 Claim form together with the statement of reasons for the referral was received on 1 June 2026. An Acknowledgment of Service was filed on 26 June, and the parties agreed a 14-day extension for the defendant’s written evidence to be filed. The Acknowledgement of Service states, “We are seeking the Court to dismiss the Claimant’s application on the basis that the test is not met given the Parole Board undertook a full 2 day hearing with a well-reasoned decision and the decision is not irrational. The Parole Board are expert risk assessors and the decision, which was a public hearing does not undermine confidence in the system.”[20]I made directions on 1 July and held a Case Management hearing 15 July dealing with; the presence of the defendant, whether the parties sought to call evidence at the hearing of the referral, provision for the filing and service of evidence to be given by the defendant (if any) and provision for evidence in reply, whether any further expert report was to be relied on and if the report(s) complied with CPR Part 35, how notice was to be given to victims of their right to attend the hearing, the victims’ rights relating to Victim Personal Statements (“VPS”), how the media was to be informed of the hearing and other administrative matters. In the event, the defendant served no evidence, neither side sought to call any oral evidence and the only further evidence served is an updated VPS from Catherine Razzell dated 27 July 2026 which I have given leave for her to rely on pursuant to r77.19(4)(b).[21]I ordered an oral hearing over two days, rather than a determination of the evidence on paper. Part 8 proceedings are reserved for cases where there is no substantial dispute of fact. Oral evidence is not commonly permitted but the Parole Board process is inquisitorial, and although I have not had to in this case, on a referral, the High Court may also need to inquire into evidence. I considered whether there is further evidence or independent expert assessment that would assist in the task. In some cases, it may be appropriate to seek and obtain evidence beyond that considered by the Parole Board but neither party has suggested any relevant evidence is missing or needs to be updated and I have concluded, at the end of the hearing, that the referral can be fairly determined by an evaluative exercise based on the evidence before the Board.[22]Irrespective of the need to receive live evidence any effective referral under this legislation should ordinarily be determined after a hearing. In Osborn (Appellant) v The Parole Board (Respondent); Booth (Appellant) v The Parole Board (Respondent) “Osborn” [2013] UKSC 61 Lord Reed provided guidance on complying with common law standards when the Parole Board makes a release decision. An oral hearing should be held whenever fairness to the prisoner requires one in the light of the facts of the case and the importance of what is at stake, in order to act compatibly with article 5(4) ECHR. No definitive list of circumstances in which an oral hearing will be necessary was provided, but an oral hearing would be expected where important facts are in dispute, or where a significant explanation or mitigation is advanced which needs to be heard orally in order fairly to determine its credibility, where the board cannot otherwise properly or fairly make an independent assessment of risk, or of how it should be managed and addressed, or where questioning of those who have dealt with the prisoner is necessary to enable his case to be put effectively or to test their views. The purpose of the oral hearing is not only to assist in the board’s decision-making, but also to reflect the prisoner’s legitimate interest in being able to participate in a procedure with important implications for him, where he has something useful to contribute[23]Consistent with that reasoning, an oral hearing was necessary in the public interest, and because GR has the right to give evidence and although he indicated he did not wish to do so, that position might have changed during the hearing. It did not. I directed that the defendant should attend by Special Purpose Licence. Provision was made that if he did not obtain the licence to attend the hearing at the Royal Courts of Justice, the hearing could take place at a court centre close to the prison so that he could be brought. As the licence was granted he attended in person accompanied by an officer and sat in the dock.[24]Provision is made for non-disclosure at CPR Pt 77 Section 2(2) and rr77.23-25 describes operation of the non-disclosure scheme. Two VPSs were the subject of an application for non-disclosure, as before the Parole Board. The request was made on the basis that disclosure of the material to the defendant would adversely affect the health of welfare of the individuals who provided the statements. The Board approved non-disclosure with the defendant being provided only with a gist of the withheld material. The gist was:
“A non-disclosure application has been submitted in relation to two Victim Personal Statements (VPS) from the victims of the index offence. The VPS’ provide details of the wide reaching emotional and psychological harm the impact of the offence has had on the victims and describes the ongoing impact the offence has had on them and their families. The VPS’ also set out the victims fears and concerns at the prospect of the prisoner’s release.”
In this referral the SSJ made an identical and unopposed application, which I granted because I judged it to be a necessary and proportionate measure. The only variation was that the material to be withheld was disclosed to his legal representatives subject to an undertaking, pursuant to r77.23(2)(b).[25]The jurisdiction introduced by Section 32ZAA of the 1997 Act is intended to support public confidence in the parole system. The hearing was in public as the High Court is required to sit in public, except where necessary for the proper administration of justice based on specific criteria in accordance with r.39.2(3). The only private part of the hearing followed the permitting of special measures pursuant to PD 1A para 10. As a consequence, a number of VPS were read in open court as envisaged by CPR PD 77 (6) (or a recording of a VPS being read was played), others were either read in private court session with the parties present but the public excluded or read/listened to in private by the judge following the non-disclosure direction. The test[26]The precise question is: Is the court satisfied that it is no longer necessary for the protection of the public that Glyn Razzell should be confined? It is to be determined by applying the codified public protection test, including whether there is no more than a minimal risk of him committing a further offence causing serious harm. The approach[27]As this is an inaugural referral to the High Court under the new statutory scheme, I set out the approach I have taken. This is not intended to be exhaustive, still less to prescribe the methodology in every future case. Each referral will depend on its own context, evidence, risk formulation and procedural history. First, the court is not exercising an appellate or supervisory jurisdiction over the Parole Board in the ordinary sense. The question is not whether the Board’s decision was irrational, procedurally unfair or erroneous in law. It is not whether the decision was reasonably open to the Board to make. The statutory question for the High Court is whether it is satisfied that it is no longer necessary for the protection of the public that the prisoner should be confined. That is an independent statutory task, although the Board’s decision, its reasoning, and the evidence before it will ordinarily be highly relevant to the court’s work.[28]The Secretary of State’s threshold decision to refer and the court’s decision on the referral are distinct. The Secretary of State must consider, among other matters, whether release would be likely to undermine public confidence in the parole system and whether the High Court might not be satisfied that continued confinement is no longer necessary. Once the case is before the court for hearing, the court must apply the statutory public protection test for itself.[29]The jurisdiction requires active and early case management. Under the modified Part 8 procedure the court will need to identify the material before it, including the Parole Board decision, the reasons for referral, the dossier of evidence before the panel, transcripts where available, any confidential or non-disclosed material, and any further relevant evidence. It should consider expeditiously whether the material is sufficient for determination, whether special advocates, live evidence or an assessor is required, and whether any issue concerning victims, confidentiality, publicity or licence conditions needs separate direction. Where necessary the evidence should be referred to in some detail because the statutory question must be answered by reference to the material as a whole.[30]The statutory test is a positive satisfaction requirement. If the evidence leaves the court unable to be satisfied - because material risk remains more than minimal, because the risk cannot be adequately assessed, or because the controls do not sufficiently manage it – the statutory consequence is quashing the release direction. The test is not a balancing exercise R (King) v The Parole Board [2016] EWCA Civ 51, [2016] 1 WLR 1947 at [31]. The sole question is protection of the public. The purpose of the determination is not to inflict further punishment for the crime, equally, the statute mandates a safety-first approach, and the fact of long-past tariff expiry is not to be weighed against risk. Age may be relevant if it impacts on risk. Favourable evidence, including compliance in custody, progress in open conditions, release planning and professional support for release, must be considered. But the ultimate question remains whether the court is satisfied that continued confinement is no longer necessary for public protection and that the relevant statutory threshold is met.[31]The court should analyse the relationship between the evidence and the risk management plan with appropriate care. The court must consider how the plan is intended to manage the identified risk, what assumptions it makes about the prisoner’s candour, compliance and insight, what external controls are available, how long they last, and whether any material risk depends on self-reporting or on matters which may be difficult for supervisors to detect. That inquiry is case-specific, but it is likely to be central to many referrals.[32]Where denial, non-disclosure, unproven allegations or lack of completed offending behaviour work are relied on, their relevance must be articulated with precision. Unproven allegations are not excluded from consideration and may be important. Unproven allegations must be approached fairly and clearly. Denial and non-disclosure under Helen’s Law are not bars or justification for further punishment. The question in each case is to be framed in whether and how those matters bear on risk, insight, honesty, victim empathy, ability to engage in treatment or supervision, and the effectiveness of licence conditions.[33]Finally, because the jurisdiction concerns the liberty of the subject and the protection of the public, the judgment should explain the route from the evidence to the statutory conclusion. It should be clear whether the court is accepting the Board’s assessment, departing from it, or reaching the same or a different conclusion for its own reasons. The objective is not to create a second parole hearing, but to give a transparent judicial determination of the statutory question Parliament has assigned to the High Court. The factual background[34]GR was born in 1959 and brought up in the Chelmsford but left home in or about 1978 to live in the Seven Kings area of Northeast London. He was the eldest of 4 children: Paul, was born in 1961; Victoria was born in 1966, and Charlotte was born in 1969. His family background appears unremarkable save that there is evidence his father had a problem with his anger management. In 1979 GR met Linda, when she was at university studying French. They were travelling on a train to Reading. Linda was a year older than GR. They married in 1984, when he was 25.[35]Linda had been brought up in a small town in Wales. Her mother died when she was eight. GR said she had been abused sexually, “suffering trauma and adversity in childhood”. It appears she had a psychiatric history, thought to be agoraphobia, and had been detained at the Goodmayes Hospital, a Low Secure unit, although information about this is scant. GR did not go to university but made his way in the world of finance working first for the Midland Bank and then, in 1984, Allied Dunbar. GR and Linda had 4 children: Catherine, born in December 1987; Matthew, in March 1990; Emma, in May 1992 and Robin, born in 1996. A relocation package at work took him to Swindon where the family settled. There is evidence that GR was controlling and violent during the marriage. On the two occasions when allegations made by Linda came before the criminal courts, GR was acquitted.[36]Linda commenced divorce proceedings in 2000, by which time GR had a new relationship with his secretary and he moved out. In December 2001, when he was 42, the defendant was made redundant. By then Linda had begun a relationship with Greg Worrall. The defendant was ordered to pay child support and on 14 March 2002 at a preliminary hearing before a District Judge, the court indicated a view of the financial proceedings which was unfavourable to the defendant. The killing happened, therefore, at a time when litigation about financial issues between GR and Linda was coming to a head. On 16 March 2002 he was served with papers freezing his bank account.[37]On 19 March 2002 Linda set out for work as usual. She parked her car in its normal place and began her walk to work down an alley between two residential streets. She has never been seen again. Her mobile phone was found lying halfway down the alley. GR was driving a friend’s car that day. Linda’s blood was later found in the boot of the car. The pattern of blood stains was consistent with a bleeding or bloodied body being in the boot. In his Report to the Home Secretary after the trial Pitchers J. noted; “At trial, the inference that Mrs Razzell was dead was overwhelming. She was a devoted mother who had made no contact whatsoever with her children since she was last seen. She had made no preparations to disappear. After some years of unhappiness, she was happy in a new relationship and was making good progress in the financial part of the divorce. Exhaustive enquiries by the police had revealed no trace of her.”[38]At his trial, and since, GR mustered several arguments which he continues to say establish his innocence. The jury convicted him. The Court of Appeal rejected his appeal. The trial judge concluded that GR had waited for his wife in the alley, bundled her into the borrowed car, disposed of the body and then set up an alibi to cover his movements. It was impossible to say how he killed her. His motive was partly money, in which he had an “obsessive interest” and partly anger that his wife was getting the better of him. In his Report the trial judge observed that the defendant, who had given evidence “came across as an extremely unemotional man who looked first the financial consequences of his actions.”[39]There was evidence of a significant degree of planning involved: his wife was wary of him, so he borrowed a car which his wife would not recognise as his, switching off his phone at crucial times so that his movements could not be tracked and probably obtaining a mattress cover to reduce traces of blood and tissue in the borrowed car. The arrangement to borrow the car (an innocent arrangement in itself) was only made for certain, the day before the killing. However, successful concealment of Linda’s remains demonstrated careful preparation. The judge found the following aggravating features; i) “A planned killing carried out in cold blood; ii) A clear intention to kill rather than cause grievous bodily harm; iii) The complete absence of circumstances which might have driven a man to a desperate act of violence; iv) Deliberately depriving four young children of their devoted mother; v) Concealment of the body.” There was no mitigation.[40]GR has not disclosed the location of Linda’s remains. He has always denied killing Linda and still suggests that she is alive and has stayed away from her children for all these years by her own choice. The profound anguish caused to the children and other members of the family of this attitude was set out with moving clarity in their VPSs at each Parole hearing. 41. In custody GR has complied well leading to a move to open conditions in 2017, before the expiry of his tariff in 2019. A financial package received from his redundancy meant that GR has been able to draw his pension since the age of 60. He has significant savings. He has undertaken little, if any, work in terms of accredited offending behaviour to address his risk factors, his position being that there is no need for interventions because there is no risk of violence. He has had employments in the community which lead to his being out of the prison, unsupervised, for many hours a week. He has acquired a flat in Ipswich, to which it seems he has had unfettered access during his time in the community. The Material before the court[42]The parties made their submissions on evidence in: 1. A Core bundle of 453 pages consisting of the Claim form and SSJ’s Reasons for the Referral, the Acknowledgement of Service, the Parole Board Decision, the Parole Board Guidance on Allegations, Ministry of Justice Policy Document on the Referral power and transcripts of the January 2026 hearing 2. A Supplementary bundle of 1,224 pages, made up of the “dossier” before the Parole Board in January together with subsequent written submissions from counsel for the SSJ and the defendant; 3. A joint authorities bundle; 4. Skeleton arguments; 5. Victim personal statements provided by Catherine Razzell, Emma Razzell, Matthew Razzell, Neil Davies, Gregory Worrall, Julie Westmore and Graham Davies (two of these in a confidential bundle, with a gist only given to the defendant).[43]The dossier contains a broad sweep of documentation. Notable in its midst are: 1. Police reports from 2000-2003 recording allegations of violence, threats and coercive and controlling behaviour within the marriage; 2. Witness statements, complaints and other prosecution material from Linda and contemporaneous witnesses such as Julie van Ruyckevelt (Linda’s sister in law) and Charlotte Razzell (GR’s sister), (including hearsay) concerning assaults, threats, coercion and financial control, and a comprehensive Wiltshire Constabulary Case Summary setting out the evidence relied on at the murder trial including the forensic findings, witness evidence and surrounding circumstances. The 2023 Parole Board considered the Case Summary an important source when examining disputed allegations in connection with risk. Collectively, these documents underpin the Parole Board’s findings in 2026 on the balance of probabilities that IPV occurred; 3. Prison records of GR’s custodial history between 2003 and 2019, demonstrating long term institutional compliance, no significant violent prison misconduct identified and progression into open conditions in 2017; 4. Numerous psychological reports, assessments and addenda from 2017 to 2026, nine victim impact statements, twelve risk, probation and custodial reports (including Multi-Agency Public Protection Arrangements (“MAPPA”)); 5. The previous Parole Board hearing decisions from 12 September 2017, 8 October 2021 and 19 October 2023 and. 6. Closing submission from the SSJ and GR following the January 2026 hearing. Evolving evidence on risk[44]The most significant timeline for risk assessment is as follows: On 16 February 2017 Dr Sian Watson reported the first modern risk formulation for the defendant. The assessment was cautious but relatively positive for future risk-reduction work. Watson found no diagnosable personality disorder and no clinically significant psychopathy. However, she identified concerns regarding control and impression management together with suspicion of professionals. She recommended work focused on relationships, emotional expression, perspective-taking, denial of offending behaviour, desire to control others, emotional expression deficits, and IPV. This further work was required before safe progression (to parole) could occur.[45]Transfer to open conditions from November 2017 became a central future of every later risk assessment because thereby a prisoner accumulates extensive successful community exposure (“ROTL”/ “ROR”);[46]Having first reported on the defendant in 2019, in April 2020 Karen Emsden, a prison-based psychologist produced a full psychology report in which coercive-control risk factors were identified. This is one of the most important documents historically. Emsden identified the central risk issues as the defendant’s controlling behaviour; deception and impression management; poor attitudes towards women; IPV and coercive control; entitlement beliefs and grievance thinking; threat to status and finances; and difficulties expressing emotions and within relationships. She used the Spousal Assault Risk Assessment (SARA) which “is “intended for use in cases where the evaluee is 18 years and older” and “in which there are reasonable grounds to believe an evaluee poses a risk of IPV, including but not limited to those in which the evaluee has a known or suspected history of IPV (Kropp & Hart, 2015, p. 11).”[47]She proposed lengthy one-to-one psychological intervention designed to improve understanding of self, relationships and emotional functioning. Her recommendations/objectives for treatment/support were, “7.56 The current assessment indicates that the key areas of work that are most pertinent currently are those related to personality and possible schemas, as well as understanding, identifying and expressing emotions. These appear to be impacting on his relationship with risk management professionals and may be related to his IPV. Ideally the following would be addressed: - Exploring entitlement, expectations, rigidity and difficulties/unwillingness to compromise; developing flexible thinking and perspective taking - Exploring schemas to help him and others understand them - Identifying and recognising emotions, exploring how he views them, experiences them, what he thinks it means to show emotions - Understanding the emotions of others - Explore self-esteem - IPV related factors (i.e. attitudes towards women, sexual jealousy, insight) - Exploring his identity, view of self and his value of status Mr Razzell may find some of the above difficult, therefore professionals are encouraged to focus on: - Encouraging him to talk about problems, explain himself and the feelings associated with the problems - Model and encourage being vulnerable, sharing feelings - Explore his expectations and associated frustrations - Encourage and reassure that sharing problems and emotions is important - Praise the demonstration of any emotions he does share, explore his experience of these emotions, and explore his experience of talking about them - Explore [h]is view of conditions he does not agree with, whilst ensuring boundaries and consequences are clear compromise; developing flexible thinking and perspective taking - Encouraging him to talk about problems, explain himself and the feelings associated with the problems - Model and encourage being vulnerable, sharing feelings - Explore his expectations and associated frustrations - Encourage and reassure that sharing problems and emotions is important - Praise the demonstration of any emotions he does share, explore his experience of these emotions, and explore his experience of talking about them - Explore [h]is view of conditions he does not agree with, whilst ensuring boundaries and consequences are clear[48]This expert opinion was accepted by the Board and has proved a benchmark against which all later progress can be measured. Subsequent reports repeatedly conclude that these objectives were never fully achieved and risk remained significant because the core drivers of the defendant’s offending remain unaddressed.[49]In August 2020 a competing psychological formulation emerges in a report from an independent psychologist Dr Terri Van-Leeson, which provided psychological support for management of the defendant in the community. It adopts a more optimistic approach emphasising what she perceived as ‘autistic features’ in the defendant affecting communication and presentation, and manageability through external controls. She saw a highly compliant prisoner who was stable in custody, his risk largely dormant in the absence of a relationship. This report demonstrates the continuation of efforts to formulate risk supervision despite GR’s denial of guilt. Despite their differences, the reports in 2020 and beyond consistently identify IPV as the principal future risk area.[50]Between May and October 2021 Emsden provided addenda developing her understanding of the defendant’s relationship-based risk and identifying the need for further work. This was emphasised by her in joint experts’ reports for the October 2021 Parole Board hearing. Van-Leeson produced another report in September 2021.[51]In June 2022 Karen Henson made an Intervention report assessing progress in psychological work. Apart from episodes of petulance one of which was described as “pushing boundaries”, he was a model prisoner. Then in January to August 2023 Emsden and Dr Kerry Beckley compiled reports which diverged in their professional opinions about risk. GR refused to participate in the preparation of Emsden’s report and his new solicitors instructed Beckley. Beckley’s opinion was based on three hours interaction with GR, she had formed the view that the killing of Linda may have been a consequence of a loss of control at a confrontation and in respect of IPV she gave weight to the acquittals. Her view was generally more hopeful than Emsden about community management of risk (if robust controls remained in place). She did not think that Helen’s Law impacted on the risk he posed but agreed that risk was moderate.[52]Emsden remained cautious, her concerns were that GR could not be managed confidently in the community. His engagement and presentational style meant that monitoring would be difficult and those responsible for him would not know what is going on in any relationship he formed. She provided the panel with a detailed guide as to how the risk he posed might be controlled on licence but wrote, "The assessment continues to indicate that Mr Razzell has the capacity to inflict a high level of harm on a partner, particularly at the point of separation or threat to status/financial situation, things not going as he wishes or potentially if someone breaches the principles he has set for them. It is not considered that this risk is imminent given his single status. Although Mr Razzell has completed some individual work this is considered introductory and he has not been asked to reflect on his offence of relationship skills. We continue to see possible offence paralleling behaviour in his relationship with professionals, as such it is considered that if he were to develop a relationship it is possible that coercive control and physical harm could be relatively imminent but that life threatening injuries would not be so. High levels of monitoring would be required including the engagement of other sources such as the new partner." And she wanted GR "to be prepared to talk about himself and his interests…he would then be more likely to talk about things which are more difficult…”[53]At that time the COM, Rick Keating-Fedders’ evidence was that GR, “does not want to lose control of the narrative.”[54]Also in 2023, an autism spectrum disorder assessment (“ASD”) was carried out by Rachel Allen who rejected the autism explanation for the defendant’s difficulties in communication and emotional expression. The traits identified were better explained by personality style, custodial adaptation, mistrust and learned behaviour than ASD.[55]The third Parole Board refusal decision in October 2023 represents the high-water mark of professional concerns. The panel made adverse findings on the question of the defendant’s internal controls and the risk to the public. It found: a) risk factors remained largely unchanged and insufficiently understood, his attitude to and conduct in future relationships remained unexplored b) GR had not completed psychological work recommended by Henson and did not acknowledge that he has any risk factors despite overwhelming evidence, this is a barrier; c) there was no compelling evidence that he had developed any internal controls, the COM told the panel little had changed since 2020; d) the OASys violence risk predictor indicates that he was a medium risk to the public in the community and known adults, risk management depended excessively on external controls (good relationships with professionals was one key) and as his insight remained poor and further relationships remained largely unexplored, disclosure of such relationships could not confidently be relied on; e) the release test was not met.[56]It analysed Emsden’s oral evidence as to why the proposed Risk Management Plan (“RMP”) would not be able to monitor all the areas which needed to be monitored, in detail, “This was due to his “engagement and presentational style.” He would not be prepared to elaborate on problems in a relationship; he would resort to using detail (his tendency to resort to detailed notes) to seek to influence people: to seek to convince them. Thus, with a new partner, he might overbear her and suggest negative things about, for example, the probation service and the criminal justice system. She added later:
“it's in his nature; he wants to control things…. If a partner reported something he would lose control.”
She cited how, in the past, he had sought to discredit Tina Jay [one of his previous COMs with whom GR had had a difficult relationship] and had indicated the way he had chosen to decline contact with herself, and how he appeared to have a “more relaxed relationship” with his male supervisors. She added that “there is something in the interaction between him and females.” [emphasis added][57]In its analysis of past behaviour, the panel made key findings regarding IPV allegations (which it considered had been insufficiently weighted previously). “1.39. The Panel accepts that Mr. Razzell was acquitted of offences of violence against Linda when he was tried at the Magistrates Court in February 2001 and then at the Crown Court in February 2002 (regarding a more serious act of violence which had occurred the previous summer). The Panel does not seek to explore the reasons how or why the acquittals came about. Nevertheless, the Panel listened with care to the answers Mr. Razzell gave to Mr. Grandison when he was questioned in detail … Mr. Razzell’s explanations, which in almost all of his accounts, portray him as the victim, are not consistent with previous accounts he has given. Moreover, they are, in themselves, in the judgement of the Panel, less than convincing. 1.40. The Panel has concluded that the evidence alluded to in those cases of violence towards his wife, however it occurred, was not isolated behaviour by Mr. Razzell. The cumulative effect of the evidence in the dossier: inter alia, the police evidence, the evidence of his children, Julie Westmore, and his sister Charlotte and Ms Ruykeveldt, in their written statements to police, all indicates, in the judgement of the Panel, that on various occasions Mr. Razzell was abusive, threatening and violent towards his wife, particularly in the latter part of their deteriorating marriage. 1.41. Thus, as Mr. Razzell’s relationship was failing, and as he and his wife were in other relationships and a divorce was approaching where there was a realistic possibility in his mind that he might lose not only his children, his house, his image of family and himself, but also his money, his wife being removed from the scene was perceived as his only option. 1.42. The way Mr. Razzell presented himself to the Panel gave rise to some concern. Mr. Razzell committed a planned instrumental murder. He has continued to assert that his wife is not dead. He presents as someone who has done nothing wrong and that the conclusions of others are wholly misconceived, despite the weight of the evidence. It has the alarming presentation of a “rigid narrative” which, if undermined, it would be impossible to say what the consequences would be. 1.43. In the judgement of the Panel these conclusions are important when considering Mr. Razzell’s risks, should he be released into the community and wish to take up an intimate relationship. Without more, the Panel cannot be sure that if, in future, on release, he were to find himself in the same set of circumstances he would be compliant and he would [not] be driven to act in the same way.”[58]Furthermore, the panel considered his “rather confrontational” approach towards two previous female community offender managers to be “offence paralleling behaviour.” The decision encapsulated the risk formulation thus, "In Mr Razzell's case his risk factors are as follows: controlling behaviour; an ability to deceive others (including impression management); entitlement beliefs and grievance thinking especially in the context of relationship breakdown and finances; negative attitudes towards women; difficulties understanding and expressing emotions, particularly in the context of relationships." The central public protection concerns were expressed as, “There is no compelling evidence that he has developed any internal controls.” And “He has done little work to address his assessed risk factors.”[59]As to Helen’s Law, “ 3.66. The Act, as amended by “Helen’s Law” must, in law, guide our approach. This Panel has concluded that Mr. Razzell has poor insight into his own behaviour (or if there is insight, he has not been open and honest and worked with professionals seeking to support him). There is ample evidence that Mr. Razzell is capable of wholesale deceit: that his wilful and deliberate withholding of the relevant information indicates that he continues to be a risk: that the reasons for his non-disclosure are relevant to the risk he presents, and the reasons carry great weight when examining the assessment of his risk should be released.”[60]Denial as a protective factor of itself was considered but the panel did not “take the view that in this defendant’s case it would necessarily be protective.” “It is the view of the Panel that Mr. Razzell will say almost anything short of admitting his culpability in crime to secure his release. This view is amply supported by the degree of deceit shown in the index offence and the construct he has built in his own mind to seek to suggest that he has done nothing and therefore will do nothing of consequence to harm anyone in the future. That, in the judgement of the Panel is false logic, because there is no certainty he will not form a relationship, and any woman (and her children) are then at high risk of harm as the relationship develops”.[61]The panel concluded that GR had failed to meet the targets the Secretary of State had set following the previous decision of the Board which had included successfully undertaking and consolidating Offending Behaviour Programmes (OBP) recommended by Henson and that he had professed a degree of contempt at what he had been expected to do. After the decision, the Secretary of State wrote to the defendant, “The responsibility for reducing the risk you may pose rests with you. The Secretary of State has undertaken a review of the information contained within your dossier and the Parole Board decision letter and after consultation with report writers has identified the following which may assist you to reduce your risk: Engage with your sentence plan and complete the objectives set. Work on developing insight into your risks and triggers and ways of reducing and managing them. Develop and maintain a positive open relationship with those responsible for working with you to address your offending behavior. Develop appropriate coping strategies and effective communication skills. Work on addressing risks relating to use of violence. Maintain positive behaviour and remain adjudication and warning free. Consolidate your learning and skills learned to date and undertake any further work identified. Work on strategies to develop and maintain positive relationships. Demonstrate ability to take responsibility for your own actions and to be open and honest with those supervising you.” Engage with your sentence plan and complete the objectives set. Work on developing insight into your risks and triggers and ways of reducing and managing them. Develop and maintain a positive open relationship with those responsible for working with you to address your offending behavior. Develop appropriate coping strategies and effective communication skills. Work on addressing risks relating to use of violence. Maintain positive behaviour and remain adjudication and warning free. Consolidate your learning and skills learned to date and undertake any further work identified. Work on strategies to develop and maintain positive relationships. Demonstrate ability to take responsibility for your own actions and to be open and honest with those supervising you.”[62]Subsequently, as one of the areas of difficulty had been his relationships with offender managers, provision was made available for him to undertake the Offender Personality Disorder Pathway (OPD) which is a joint Prison Service and NHS England therapeutic initiative. The guidance indicates OPD is usually reserved for complex cases of people who are difficult to manage, with a clinically justifiable link between a personality disorder and the risk they pose. Although in his evidence to the panel in 2023 the defendant rejected the OPD because he does not have a personality disorder, following refusal of parole he changed his mind. In 2024-2025 Lucy Overton, a senior psychologist carried out a programme of approximately 20 sessions involving the defendant, and new prison and probation staff. Their purpose was: improving professional engagement; promoting openness and assisting supervision. She expressed continuing concern regarding the defendant’s emotional awareness, empathy and interpersonal functioning. Overton emphasised that this was not a risk-reduction intervention.[63]On 19 December 2025 Lindsay Leigh a prison-based psychologist, provided a full psychological risk assessment. The defendant had continued to achieve extensive ROTL grants. Her key conclusions were that the defendant’s risk could potentially be managed in the community; extensive supervision would be required for years; any new relationship must be disclosed immediately; major gaps in understanding his risk (by him and those responsible for him) remained; internal risk factors have not been adequately reduced; lack of insight is a significant limitation; and, release is dependent upon meaningful future engagement.[64]Finally, in January 2026 extensive risk management material was assembled. This included Leigh’s formal risk analysis, an OASys assessment dated 7 January 2026 which concluded GR posed a medium risk of causing serious harm in the future, a POM report dated 19 March 2025 & updated on 8 January supporting release subject to management conditions and structured supervision, COM report dated 31 March 2025 & updated on 6 January containing community assessment and proposed risk management plan, also supporting release but recognising the need for extensive monitoring, and MAPPA assessment proposing intensive licence conditions, level 3 oversight and long-term supervision arrangements.[65]Overall, by this time the professional consensus had shifted towards release being manageable, albeit with important caveats. This was predicated on the same risks being in place as identified by Emsden. What had improved the defendant’s position was steadily accumulating evidence of compliance in open conditions (by now, for eight and a half years), many hundreds of successful ROTLs, successful Approved Premises testing, positive work reports, an absence of violent incidents and extensive community exposure without adverse events. Probation staff within and outside prison increasingly viewed these as significant evidence concerning practical risk management.[66]At the 19 and 29 January 2026 hearing the panel received evidence from Lindsay Leigh, Lucy Overton, Fran Rawlings the COM, Liselotte Jouhki the POM and the defendant. Afterwards, written closing submissions on behalf of the SSJ argued that risk reduction work remained unfinished and release depends excessively on trust and self-reporting, those from GR challenged the psychological formulations relied on by the SSJ, maintained his innocence of the murder and contended that future community work was the appropriate way forward.[67]Notably, across all the reports there is remarkable consistency about the defendant’s inherent identified vulnerabilities: his need for control; rigidity in thinking; emotional restriction; focus on impression management; his status sensitivity; difficulties in intimate relationships; and problems dealing with challenge or criticism. The true disagreement is not over the nature of the risk factors but whether his denial impedes meaningful formulation so that important work, including on insight remains incomplete, and whether compliance with external controls and successful community testing can safely substitute for internal insight to demonstrate reduced risk. The Parole Board’s approach to the unproven allegations in January 2026[68]At the start of the first day of the hearing, 19 January 2026, the panel followed a methodical approach in considering the unproven IPV, including that which had been the subject of acquittals. It had the benefit of Linda’s witness statements for those charges that had gone to court and stated that it was obliged to look at the allegations afresh, applying a different standard of proof and making findings of fact, not findings of guilt. It also explained that it had a fuller evidential picture than previous panels which had referred to this background material. The SSJ had provided preliminary submissions on the evidence available. Some of the evidence and one of the allegations therein relied on the content of VPSs and SSJ withdrew reliance on that evidence and amended the allegation. The defendant had not addressed these matters in his written document to the panel and was cross examined by counsel for the SSJ.[69]Allegation 1: assaults on 30 April and 1 May 2000. GR was alleged to have thrown Linda against a wall, grabbed her by the hair, thrown her into a room, banged her head into a mirror, then the following day hit her head on the kitchen wall, threatened to kill her, grabbed her hair again, thrown her backwards, kicked her and fractured her rib. This was based essentially on Linda’s statement of 22 August 2000, with support from what their young son Matthew told Charlotte Razzell, "Dad, I saw your foot come up and you kicked Mum." and from Julie van Ruyckevelt’s evidence that GR had admitted assaulting Linda. "Glyn was sitting, he was very flat and expressionless... he said he did it, assaulted Linda because he was depressed..." The panel found the accusation proved on the balance of probabilities, saying there was “ample evidence” supporting Linda’s account.[70]Allegation 2: 21 August 2000, GR was said to have kneed Linda in the backside where she had a cyst and threatened to kill her. This allegation had been the subject of a magistrates’ court trial for assault occasioning actual bodily harm. The defendant said this was a false allegation. The panel did not make a definite adverse factual finding because it could not know what evidence contrary to Linda’s account had been before the court and because of the acquittal. However, applying Pearce, and its own Guidance on Allegations, it found a serious possibility that the allegation was true, considered it relevant to risk, and attached some weight to it. To Emsden, in 2020, the defendant had said, “6.9 In relation to the common assault for which he was acquitted he stated “we had a court case coming up, she was about to be thrown out of the family home, she alleged the assault to get me out of the family home, which was extremely successful. Two of the three [accusations] came just before a court hearing” [38], with Mr Razzell suggesting that Mrs Razzell and her solicitor chose the timing to improve their position in court. “[71]Allegation 3: 19 May 2001. After finding Linda’s new partner in the house, GR threatened to kill her, used force against her in the porch, and caused her head to strike/break the glass door, causing injury. The panel recorded that GR had gone to the police station bleeding heavily and said, “I pushed my wife through a pane of glass, I didn’t mean to.” He was acquitted by a jury in February 2002. In his evidence to the panel the defendant admitted the push with considerable force, but it was not intentional. On the balance of probabilities, the panel found that on this occasion GR used unlawful force causing Linda injury. To Emsden, also in 2020, he had said, “6.8... In relation to the GBH offence for which he was acquitted he described in interview “she was blocking my exit from the house and I shoved her out the way, gradually swiped her out the way, she suddenly went from standing and resisting to going backwards, possible the mat slipped on the tiles. She went through the window backwards, Greg [Mrs Razzell’s partner at the time] was present, my hand went through the window. That’s what prompted it, Greg had moved in which had financial implications for the divorce and she was annoyed I had found out” [38]. He clarified that there was no aggression or violence from him. “ The panel noted that he had given a somewhat different account to a psychologist in 2023, namely that Linda had thrown herself through the glass panel and pulled him through with her.[72]Allegation 4: wider violence during the marriage. This report was that GR had been violent on several other occasions. The panel relied on Linda’s statement of 20 May 2001 describing incidents including grabbing her head and bashing it against a wall, door or mirror, supported by evidence from Charlotte Razzell and Julie van Ruyckevelt. As before, the panel found Linda’s witness statements significantly more reliable than GR’s evidence and concluded that the totality of the evidence supported the proposition that he used violence against her on several occasions during the marriage.[73]Allegation 5: financial control. GR accepted that during the financial dispute in the divorce proceedings he stopped making payments to Linda and the children despite having the means to do so, and the panel characterised that as a deliberate and manipulative act. The panel treated this as significant because GR accepted he was using financial controls to influence Linda’s attitude to the s.20 Offences Against the Person Act 1861 charge he faced in the Crown Court (shortly before her death) (Allegation 3) regardless of the effect on her or the children. It also treated his comment that Linda was “wrapped up in trying to harm him” as part of a thread of blaming and demeaning her.[74]The defendant denied any gratuitous violence towards his wife or anyone else. He said that Linda made lots of false allegations. He maintained throughout his submissions to the 2026 panel and cross examination by counsel for the Secretary of State on the allegations summarised above, that Linda had never been frightened of him and she didn’t even carry an attack alarm which the police had given her, with her (he said it was found in a drawer by her bed after her disappearance.)[75]A flavour of the defendant’s account to the panel when he was asked about some of these in January 2026 is captured in this section of questioning about Allegation 1, “she was carrying Robin, she ran out through the utility room, past the utility room door, which may have been when she cracked her rib and fell on the patio. And I followed her out because there’d been a pattern of behaviour where she had been running out of the house and driving off at speed with the wheels spinning on her car and I’d let her do that but I didn’t want her to do that with Robin as well so I went after her on that occasion to take Robin from her which she didn’t fight to hold Robin or anything like that. So, I just picked him up from her and she went off wheels spinning. T JONES: What was she running from? G RAZZELL: From herself, she was in a, she’d lost control. T JONES: She was carrying Robin, who would have been four at the time, is that right? G RAZZELL: Yes, three, three and about five months. T JONES: So, she's carrying a three-year-old, running with the three-year-old and then slipped over, that's your account of what happened? G RAZZELL: Yes. T JONES: She was running, Mr Razzell, because you had hit her head on the wall and threatened to kill her and thrown her backwards wasn’t she? G RAZZELL: I wasn’t charged with threats to kill, it was, I know this is in her lurid account of things, it’s just wrong. I don’t have, it doesn’t matter, it just doesn’t matter, I'm the prisoner, everyone’s going to assume that I'm lying anyway as they have all the way through, what is the point in my quibbling? You know, it’s, it just makes no difference. T JONES: And Matthew would have been about 10 at the time, is that right? … T JONES: So, can we look back then at what you told Charlotte please, page 731? And if we start please towards the bottom of that page where she says, ‘I spoke to Matthew afterwards and he felt so guilty that he couldn’t hold the door closed and stop his mum being hurt’. He felt guilty because he couldn’t stop you from attacking his mother didn’t he? G RAZZELL: No, but this is all irrelevant, and that phone call was when I was walking round Badbury Clump with Linda after, I don’t recall when it was, but that when Charlotte was there and Linda was quite willing to go for a walk round the woods with me for hours. And in terms of the conversation with Matthew I didn’t want to, you know, contradict Matthew or argue with him, that, so I would have agreed anything that he said. T JONES: So, he did say to you then did he, ‘Dad, I saw your foot come up and you kicked Mum’? G RAZZELL: No, he didn’t say that. ….So I'm agreeing that I had a phone call with Matthew and he'd have said something like, ‘I saw you attack Mum’, but there's nothing, no, there's no detail like that. And I think it’s mischievous of Linda’s sister-in-law really or I think it was actually Charlotte, my sister, Charlotte’s not very reliable. T JONES: He said to you that he saw you attack his mum because it was true, he had seen you attack his mum hadn’t he? G RAZZELL: No, but he'd seen me follow her out and then he'd have heard her version of events after the police had come and evicted me from the house and so in his mind Linda’s version of events and the police evicting me is what happened. But it doesn’t matter, I'm going to be, it’s going to be assumed that I was violent in the marriage anyway and for the purposes of my release plan, you know, I don’t see how the Parole Board can assume anything else in setting parameters and conditions for me. T JONES: … The next point I want to ask you about is Ms Van Ruckervelt’s evidence, …. ‘After the assault Glyn had run away’? And you'll see there that what Julie says is, ‘Linda desperately wanted to know if he was depressed as he claimed, genuinely ill or if he was playacting to get sympathy or maybe some sort of control over her’. So, at that point Linda was trying to get to the bottom of your behaviour wasn’t she? She was not trying to spin a story to help with potential divorce proceedings? G RAZZELL: I don’t think that Julie has given an honest account, but it was 20 years ago and it’s all water under the bridge now. T JONES: …Julie records that you admitted what you had done to Linda and that is true isn't it, you did on that day admit to Julie what you had done and in particular that you had kicked Linda and caused a fractured rib? G RAZZELL: No. But, but I don’t think I challenged it because Graham[?] and Julie had come to visit us at Pentylands and I was still at that stage hoping for a reconciliation in our marriage and, you know, calling Linda a liar to her brother and sister-in-law, you know, wouldn’t have helped any reconciliation. So, I think I fudged it.” followed her out because there’d been a pattern of behaviour where she had been T JONES: What was she running from? T JONES: So, she's carrying a three-year-old, running with the three-year-old and then slipped over, that's your account of what happened? T JONES: And Matthew would have been about 10 at the time, is that right?

divorce proceedings?

[76]Overall, the panel concluded that the murder should be seen as the extreme culmination of a relationship in which the defendant sought to control Linda and used violence against her on several occasions towards the end of the marriage. It considered that of the two motives suggested by the trial judge, money and anger that Linda was getting the better of him, the latter was the more powerful. Notable features of the professional evidence before the panel[77]Liselotte Jouhki’s report described GR’s positive engagement with her as his POM which she considered genuine. She discussed the work done with the psychologist Lucy Overton which ended in December 2025. GR had described the sessions as a ‘safe space’ where he could fully engage and she did not find him attempting to control them. Continuing the OPD sessions in the community would benefit GR. She described the very considerable temporary leave (1245 ROTLs of a variety of kinds including for work) he had accumulated successfully and positive comments about his support for other prisoners who had appreciated his help. On managing risk she wrote, “I have had sight of the PRA completed by Lindsay Leigh in December 2025. I am aware from reading the report that there are concerns related to external factors and managing these risks, especially as he has maintained his innocence so there are difficulties assessing specific areas of risk. however, it is also highlighting changes with his attitudes and how having a robust risk management plan would also address these external risks. I concur with the areas within this report which discuss factors which would be supportive of his risk management, specifically with future relationships. Mr Razzell is aware that he would be required to disclose any form of developing relationship, whether this is intimate or not, and he has emphasised his desires to never enter into a relationship ever again. However, he has accepted probation views, especially with ensuring that he is aware what this condition requires and what he must do, he has displayed knowledge and understanding of things which are expected of him related to relationships. Since working with Mr Razzell and having sight of previous reports, he has continued to maintain his innocence, and he does have strong views on this. He does not let his views interfere with professionals working alongside him. Despite his views, he has emphasised the importance of compliance with all conditions put towards him, and the willingness to accept that there will be future restrictions on him and what they would entail. “ I would be supportive of Mr Razzell to be released to the community. I believe the test of public protection has been met and the risks he poses can be managed with the risk management plan which has been put forward. Mr Razzell has remained at Hollesley Bay for an extensive period of time, during this time he has accessed numerous ROTLs and spends a significant period of his time in the community through ROTLs and outside work. Mr Razzell has come across difficult periods such as deaths in the family, negative outcomes from parole and this has not changed his behaviours or raised concern. Mr Razzell has engaged and completed extensive work and within this explored attitudes, behaviours and relationships. This is work which can also be continued within the community which would continue to address any areas of concern. Mr Razzell has emphasised the importance of compliance to him, I do believe he would comply with the licence conditions put forward and address any areas of concern to professionals, he is aware of the consequences of non-compliance with any conditions. He has evidenced a lengthy time with positive compliance and feel this would continue in the community.”[78]In oral evidence she said she had taken the unproven allegations into account as well as GR’s continued denial of the murder but when challenged by a member of the panel as to whether (given his denial of the murder) she believed GR had simply been lying to the professionals during the Overton sessions she said, “I don’t believe Mr Razzell’s been lying. I think, obviously I do believe he’s worked hard with the professionals we’ve asked him and he has put a lot of work into the year that we were doing. I think it’ll be quite hard to complete that quite a length of work for a year, multiple appointments in a month sometimes, and continue to lie about things. I believe that he believes that’s his truth, so he’s very persistent with his theories. I don’t think that changes the way that we would be working with him in our meetings and- F AINSWORTH: But you don’t believe it’s the truth or you think it might be the truth? L JOUHKI: I believe Mr Razzell believes it’s the truth…” L JOUHKI: I believe Mr Razzell believes it’s the truth…”[79]She said they had not been focussing on the offence directly but exploring his perspectives on relationships to understand him a little more. She was asked if there had been any occasion on which he had taken responsibility for any unhealthy behaviour towards his wife. He had not. Similarly, as to his children. “Mr Razzell doesn’t believe he poses any risks. We’ve explored what risks could look like and if there was any incidents that he could feel that he could be a risk, which he continues to deny. He accepts that we have our own assumption on what his risks are and he accepts those are the ones that we’re going to manage.”[80]She was asked if he had ever shown himself in a potentially negative light ie where he wasn’t ‘perfect’ and although she said he tried to solve problems she could not think of a single incident in which he had put himself in a negative light in the two years she had known him. Critically, she agreed that he hadn't actually done any rehabilitation work on domestic violence or murder and she was concerned about that, but she still viewed the risks he posed as being manageable in the community despite that work not having been completed. She considered that one to one intervention which would be a ‘skills for relationships course’ could be the vehicle for that.[81]His Honour Paul Thomas asked her, in light of the fact that he had not done any treatment on how he would respond to a loss of control, how that would be managed and she said it would be managed as something that might arise in the dynamics of a relationship and that was “an assumption or assessment” of the risk that the professionals had made. She was then asked whether she believed that she really understood his offending and she believed she did “I think obviously there's areas that will always remain gappy obviously with his maintained innocence, that we don't have information on... But at the same time, I believe that even with maintained innocence there are risks that are identified with Mr Razzell's case that can be managed from what we know of him.” She was asked what they were, “I think it would be in a relationship, if there was a separation or withdrawal of commitment from the partner and he felt that there was no kind of, he was losing control again of the situation, if he wasn't able to control a situation that he was in, if there was expectations that he was wanting that weren't being met, then obviously things are being held or being taken away from him such as his children, his finances and just breakdown of relationships. Judge Thomas: How do you know, in the case of somebody who did not kill because of an emotional breakdown, in what circumstances he might kill again? L Jouhki: Well, I think the licence conditions that we would have in place would monitor and restrict him from having access to be able to potentially do that again. If he was to enter into a relationship all the information of that potential partner would be known.”[82]She said they would monitor developing relationships and the assumption they made was that the only risk he presented was in the context of the breakdown of a relationship. Later she was asked whether she'd had any discussion with the defendant about the ongoing harm that may be caused to Linda’s family and friends by him maintaining the website about his case website “Justice for Glyn Razzell” and a link to the documentary that had been made. She said they'd had a conversation about the harm it would cause and he had empathised with the harm it had caused the children, but he did not take the website down and they had not discussed that. He intends to keep looking for Linda as his website indicates and they had discussed with him the harm that would cause for his family and Linda’s friends. When asked why she didn't believe that that attitude was a block to his being released and why it didn't set alarm bells ringing for her she said that she believed the defendant thinks he is being helpful even though that attitude had been challenged. She agreed it was concerning that he continued to press that he wants to look for Linda, and he didn't realise that it seemed to be causing ongoing harm. But her final position seems to be that the defendant hadn't been actively posting on the website with intention to cause harm to his children or anybody else[83]Lucy Overton, had conducted 20 sessions (of 1 or 1 ½ hours each) with GR, all including Jouhki and half of them including Fran Rawlings the COM. She did not provide a formal report but in her two letters to the panel, she made it clear that the purpose of the sessions had been to support the defendant's new POM Jouhki to develop a therapeutic rapport with him because he had had difficulties in engagement with staff, and to “assist those managing his future risk to work with him meaningfully. This work was not designed to be an intervention and as such we did not complete or comment directly on risk reduction work but instead explored with Mr Razzell his role and behaviour within past familial, non-intimate and intimate relationships and his place in those relationships to gain a better understanding of him. We also explored with him towards the end of our sessions how he might utilise his increased awareness of himself to ensure he manages any future risks or difficult situations effectively.”[84]Accordingly, they had “adopted a compassion-focused therapeutic inquisitive approach to questioning which allowed Mr Razzell to, without fear of judgement, explore and answer all questions put to him about his past”. This had enabled GR to relax and be less controlled than he had previously been with professionals while in custody. They worked through a timeline of his life and used it as a tool to create an environment in which he was able to speak freely about his life and how others might have seen him.[85]In her evidence Overton was asked if the work they had done had reduced his risk and she said, quite frankly, that she could not comment on that. Plainly, it was not expected or intended to do so.[86]Lindsay Leigh a prison psychologist, provided a Risk Assessment Report dated in December 2025. In her executive summary she wrote, “2.1 I have considered risk and need of [IPV] using Structured Professional Judgement tools (SARA-V3 and SAPROF) and conclude that the case prioritisation can be considered moderate which indicates the level of resource required to enable effective collaborative risk management. I have used a variety of methods to inform my professional opinion using including evaluation of the collateral material, factual and professional opinion, discussions with professionals involved in case management, within peer supervision with those not involved in case management and in-depth clinical interview with Mr Razzell (approximately 17 hours including the disclosure interview.) 2.2 Mr Razzell continues to deny he committed the index offence, maintaining his innocence. This is a limitation that is significant in this case especially when considering the limitations in assessing risk more generically. [emphasis added] 2.3 Helens Law is a consideration in this case, and I have outlined potential hypotheses in to understand denial, minimisation, justification and blaming and how it links to disclosures. These remain untested. 2.4 I have considered risk management in both custody and community and concluded that on balance risk could be closely monitored and supervised with intervention in the community if Mr Razzell meaningfully engages with these processes. I outline how assessors can evaluate this within the report. I have considered in detail what the measures of risk management should and needs to entail. This is not exhaustive and will need regular review. Any changes in behaviour or consistent behaviour as outlined in the formulation linked to sense of self, other people or the world needs to trigger an immediate review of risk and need. It is my opinion that the proposed risk management strategies need to be fully implemented in the long term, years not months. 2.5 Risk is understood within the context of IPV and any new relationships, either intimate or non must be disclosed immediately by Mr R so he can be professionally supported and my view is that victim safety planning is critical in this case. 2.6 If Mr Razzell is not able to engage meaningfully with the needs outlined within this assessment then I recommend he remains in custody or if in the community risk assessment takes place to consider what external measures will be required to manage risk.”[87]She described the limitations to her work in this case, “4.5 There are limitations with this assessment that I would like to highlight. Mr Razzell is maintaining his innocence and has consistently said he did not murder his wife nor commit any abuse or violence towards her during the course of their relationship. This reduces confidence in the assessment as we (as in Mr Razzell and I) have not been able to collaboratively formulate risk and needs considered pertinent in recidivism for intimate partner violence as he does not believe any are present or relevant. Denial, justification, minimisation and blaming are not uncommon among people who commit IPV and indeed are seen as a risk factor to be considered within the SARA. I have referred to Guidance on Prisoners who maintain their innocence (Parole Board, July 2024) and Guidance on Allegations (Parole Board, September 2023) to help structure my thinking.”[88]Leigh noted the evidence of previous IPV and in particular Linda’s statement that there had been violence on at least a dozen occasions in their marriage, while the defendant told her that it was Linda who used violence and would be emotionally dysregulated. He also said that she lied and manipulated others, turning the children away from him eg. As to future risk Leigh wrote, “6.9 Risk Formulation. 6.10 Psychological risk formulation aims to provide an essential context for the outcomes of the report, including the assessments used, the risk factors identified and the conclusions made. By illustrating the likely meanings and functions behind offending behaviour, ongoing risk prediction and risk management can be planned. The aim of a formulation is a shared understanding, it assists goal setting, and a map for change. A key component of a meaningful formulation is collaboration, working ‘shoulder to shoulder’ with a client, discussion and testing of hypotheses and agreeing a joint understanding of meaning. This is a significant limitation of this formulation as Mr Razzell believes he is wrongly convicted and hence has no risk or needs linked to IPV, so it is difficult to agree a shared understanding.[emphasis here added] Mr Razzell’s risk and presentation has been comprehensively formulated within previous psychological assessments as cited in the report (Dr Watson, 2017; K Emsden 2020; 2023; Dr Van Leeson 2020; Dr Beckley 2023). I have reviewed these and broadly agree with the considerations of risk within these and refer the reader to these previous assessments. This formulation has been developed from reading the collateral information contained within the dossier, including professional reports and witness statements, completing structured professional judgement tools, namely the SARA-V3 to consider risk and vulnerabilities and protective factors using the SAPROF framework and clinical interview with Mr Razzell. I have used the ‘5 Ps Model’ of formulating risk as a way of summarising the pertinent risk and protective factors. 6.11 Presenting Issues: these are current problems or behaviours relevant to risk. The presenting issue is severe IPV that Mr Razzell is convicted of murdering his estranged wife, Linda. They had separated and were in the process of a protracted acrimonious divorce process. The last Parole Panel (2023) summarised the ‘index offence as characterised by instrumental violence, significant planning and boundless deception’ and that the account he gave about coercive control is at odds with the weight of evidence. Distorted Thinking about IPV is present and relevant; Mr Razzell does not accept any abusive behaviour towards Linda or that he murdered her. He says that Linda was violent and abusive towards him and that she lied to others about him and was manipulative. Mr Razzell’s view is that this is not distorted thinking, it is the truth and it is clear he believes his narrative and can feel frustrated that he is not believed. Risk factors of relevance include controlling behaviour (intimidation), an ability to deceive, including by impression management, unhelpful thinking in the context of relationship breakdown and finances, unhelpful attitudes towards women, and difficulties experiencing and expressing emotion. [original emphasis] The difficulty being that Mr Razzell does not accept any of these factors as having been present in the past or currently and having no relevance to risk management. 6.12. More recent presenting problems, but not in the last 24 months include the consideration of potential offence paralleling behaviours; ruptures in professional relationships, pushing boundaries, unhelpful behaviour such as having difficulty compromising/seeing others perspectives, presenting in a rude or dismissive manner, unwilling to discuss emotions, being mistrustful of professionals or the ‘system’, over-controlled but leaking frustration in an unhelpful manner. Mr Razzell does not recognise these behaviours and tends to consider the issues being a problem with others and not himself. It is to his credit that evidence of such behaviour has not been observed as present in the last two years. It is possible that when Mr Razzell is dysregulated, ‘has his buttons pushed’ or ‘triggered’; when he does not feel he is in control or has some control over an issue or a situation, is not able to achieve what he perceives as ‘perfectionism’ and begins to criticise himself and a way of coping with this is to project this externally.” 6.10 Psychological risk formulation aims to provide an essential context for the outcomes of the report, including the assessments used, the risk factors identified and the conclusions made. By illustrating the likely meanings and functions behind offending behaviour, ongoing risk prediction and risk management can be planned. The aim of a formulation is a shared understanding, it assists goal setting, and a map for change. A key component of a meaningful formulation is collaboration, working ‘shoulder to shoulder’ with a client, discussion and testing of hypotheses and agreeing a joint understanding of meaning. This is a significant limitation of this formulation as Mr Razzell believes he is wrongly convicted and hence has no risk or needs linked to IPV, so it is difficult to agree a shared understanding.[emphasis here added] Mr Razzell’s risk and presentation has been comprehensively formulated within previous psychological assessments as cited in the report (Dr Watson, 2017; K Emsden 2020; 2023; Dr Van Leeson 2020; Dr Beckley 2023). I have reviewed these and broadly agree with the considerations of risk within these and refer the reader to these previous assessments. This formulation has been developed from reading the collateral information contained within the dossier, including professional reports and witness statements, completing structured professional judgement tools, namely the SARA-V3 to consider risk and vulnerabilities and protective factors using the SAPROF framework and clinical interview with Mr Razzell. I have used the ‘5 Ps Model’ of formulating risk as a way of summarising the pertinent risk and protective factors. 6.11 Presenting Issues: these are current problems or behaviours relevant to risk. The presenting issue is severe IPV that Mr Razzell is convicted of murdering his estranged wife, Linda. They had separated and were in the process of a protracted acrimonious divorce process. The last Parole Panel (2023) summarised the ‘index offence as characterised by instrumental violence, significant planning and boundless deception’ and that the account he gave about coercive control is at odds with the weight of evidence. Distorted Thinking about IPV is present and relevant; Mr Razzell does not accept any abusive behaviour towards Linda or that he murdered her. He says that Linda was violent and abusive towards him and that she lied to others about him and was manipulative. Mr Razzell’s view is that this is not distorted thinking, it is the truth and it is clear he believes his narrative and can feel frustrated that he is not believed. Risk factors of relevance include controlling behaviour (intimidation), an ability to deceive, including by impression management, unhelpful thinking in the context of relationship breakdown and finances, unhelpful attitudes towards women, and difficulties experiencing and expressing emotion. [original emphasis] The difficulty being that Mr Razzell does not accept any of these factors as having been present in the past or currently and having no relevance to risk management. 6.12. More recent presenting problems, but not in the last 24 months include the consideration of potential offence paralleling behaviours; ruptures in professional relationships, pushing boundaries, unhelpful behaviour such as having difficulty compromising/seeing others perspectives, presenting in a rude or dismissive manner, unwilling to discuss emotions, being mistrustful of professionals or the ‘system’, over-controlled but leaking frustration in an unhelpful manner. Mr Razzell does not recognise these behaviours and tends to consider the issues being a problem with others and not himself. It is to his credit that evidence of such behaviour has not been observed as present in the last two years. It is possible that when Mr Razzell is dysregulated, ‘has his buttons pushed’ or ‘triggered’; when he does not feel he is in control or has some control over an issue or a situation, is not able to achieve what he perceives as ‘perfectionism’ and begins to criticise himself and a way of coping with this is to project this externally.”[89]It was her opinion that the issues described as vulnerabilities were seen as strengths by the defendant. She recognised that there are protective factors: GR wants to be released and has shown an ability to comply with rules and regimes, he has been in open conditions for over 8 years and has brought some difficult issues to those supervising hymns such as speeding offences. He seems willing to discuss what he thinks about measures such as external controls and wants to understand why they are applicable to him so that they make sense to him while in previous times he had railed against them. He has strong relationships with his siblings. Overall, then, “6.16…There is evidence of a good level of protective factors in place, but any deterioration could impact on their quality and value. For example, if he continues not to understand why a measure is in place for risk management purposes, does not ‘buy into their value’, there is a risk compliance is not meaningful in a way that helps him manage risk, or is superficial, especially in light of his belief that he is not a risk or that how he might cope with issues is adaptive. Having said that, this has been tested successfully in open conditions in recent times.”[90]On potential scenarios for re-offending Leigh postulated various examples including a (not unrealistic example for a man of 66 who had enjoyed intimate relationships in the past) a repeat of the deteriorating relationship leading to conflict and IPV. “6.20 If he were to form a relationship with someone who was doing something he did not want or is not thinking or behaving according to how he sees things, not able to abide by his ‘ways of doing things’, this could lead to conflict which may not be able to be resolved. This might not be resolved using practical strategies, which could potentially lead to IPV, including physical, emotional or psychological harm. It is possible Mr Razzell finds it difficult to cope with perceived slights, criticism or rejection, which in itself would not be an issue if there was insight and a shared understanding of this as a vulnerability and an understanding of the internal processes of coping with this which do not rely on practical or avoidance strategies. Lack of insight on this is critical.” [emphasis added.][91]Another hypothesis was killing in such a situation to prevent disclosure of difficulties to supervising staff which he might fear would trigger a recall to prison and a ‘best case scenario’ in which the defendant lived in the community engaging meaningfully with those responsible for his supervision, being able to ask for help, feeling safe, being able to use supervision sessions as a reflective space to consider things going well and not so well, reflecting on strategies that work well for him and being able to apply these over time. He would have to be prepared to accept feedback about the relational process of a working relationship, being prepared to hear things which he may perceive as slights or criticism, being able to share when “his buttons are pushed” and so on. Leigh noted that overall, the risk of IPV generally decreases as people get older.[92]The risk of IPV was not imminent as he is not in a relationship while in custody but, “6.26 I agree with other assessors with the warning signs which could be observable. However, as we do not have a shared understanding of IPV within relationships, it is possible that harmful behaviours could commence at the more earlier stages of a relationship. These maybe less observable by professionals or a partner or potentially by Mr Razzell. A partner must be engaged with professional services from the commencement of a relationship.” [emphasis added][93]She provided a list of potential danger signs and a summary of risk assessments using the various tools available. The codes relating to spousal violence indicated a medium risk to the public and known adults and the current dynamic risk assessments including SARA indicate prioritisation as moderate or elevated albeit within the caveat of a significant limitation in assessing risk when there is not a shared understanding of risk with the subject of the testing. She said “there are gaps in understanding, and many hypotheses remain untested as to how and why the offence took place. A more shared understanding could change this categorisation.”[94]Turning to an assessment of what progress GR had made and future work she reported that some progress had been made when he willingly engaged in the Overton sessions. Whilst that was not an intervention it was evidence of an ability to engage and discuss matters relevant to formulating risk and need. She said this had been challenging work for the defendant, and it was to his credit that he had collaborated and felt safe within the team. She then returned to Emsden's 2020 list of topics referenced earlier [47] and noted that while those targets were not specifically addressed within the sessions, there had been a willingness to consider the themes around them. While the defendant was disparaging when discussing the work he had done with Henson which he said he found patronising and from which he said he learnt nothing about himself and he didn't complete the worksheets, nor was he able to describe what he had learnt about his schemas and modes, she considered that the picture was now somewhat different and he seemed to have less of an effective intolerance towards Emsden's list. She said it was difficult to evaluate what had changed with any confidence. It could be evidence of flexibility developing and that could be seen as progress. She went on to qualify the progress however, “6.36 The issue remains that he does need to collaboratively work towards achieving the aims to demonstrate risk reduction and further development of protective factors. There are too many gaps, limits in shared understanding and this can impact on the efficacy of risk management strategies. At present there is a heavy reliance on external measures of control and development of the internal factors as described above needs to take place to more confidently assess risk, need and measures involved in risk management. I also believe that they will enable and give confidence to Mr Razzell and help him rely less on avoidance and practical approaches to manage life’s problems.” [emphasis added][95]Helen’s Law was considered, “6.41 A key question in understanding risk of recidivism, need and risk management pathways in this case is the role of denial, minimisation, justification and blaming (DMJB)… The evidence of a potential link between DMJB and IPV recidivism is mixed, perhaps due to the various forms the constructs can take, the differing potential motivations and the difficulty in measuring them meaningful. One of the difficulties in understanding it is that it can be used as an abuse tactic to control the response of partners. Not understanding the role of providing a distorted account impacts on the manageability of risk and the usefulness of rehabilitative attempts. A recent systematic review (2023) of the primary research related to DMJB in heterosexual men who commit IPV supports a model of it that is multi-faceted and complex. Critical findings indicate it serves a complex function for men who abuse female partners; it facilitates abuse, while also serving a self-protective function, and can be used instrumentally, although the evidence for this aspect is less clear.[96]She also described various hypotheses for the function in GR’s case of his maintaining innocence of Linda’s murder, without reaching any opinion as they all remain untested. Finally, her opinion was, “7.3…I have concluded that an overall coding of moderate/elevated case prioritisation which should increase to high during times of transition with commensurate resource to manage this. As outlined in the main body of the report there are limitations and hence reduced confidence in assessing risk and need, given the gaps in understanding, lack of insight and unmet need outlined. 7.4 I have discussed costs and benefits of placement; in open conditions and the community. 7.5 It is my view he will comply with risk management strategies as long as he understands their rationale. He may be less willing to comply with measures he does not consider as proportionate but recognises he will have little choice. The quality of the engagement as well as the ‘quantity’ of it needs to be monitored. 7.6 Helens Law is applicable to this case and I have given opinion on understanding the maintenance of innocence and the functional link to risk. All of the hypotheses considered (and untested) could be considered as offence paralleling behaviour. 7.7 I have considered the new test for release ‘the codified public protection test’ (3 February 2025) which states that parole panels must be satisfied that if the prisoner were no longer confined, that there would be no more than a minimal risk that he or she would commit a further offence which could cause serious harm. 7.8 I have outlined what needs remain unmet, the progress made which seems reflected in behavioural change and how they can be achieved, the focus on external measures of risk management, which in my opinion should be fully implemented in the long term (years not months) and the need to further increase internal measures. Much of the efficacy of this is dependent on Mr R’s understanding and engagement with it. In my opinion whilst there is some benefit of this continuing in custody on balance this can potentially be achieved in the community via close supervision measures which contain an intervention function as well as monitoring. The quality of the therapeutic alliance should be consistently evaluated and any ruptures and ability to repair considered in terms of risk and need. Supervisors should expect some behaviours such as avoidance, relationship issues and willingness to discuss and resolve these meaningfully needs to take place. Any change in the efficacy of this approach to risk management should trigger immediate re-assessment of risk and consideration of how risk and protection of the public can be managed.”[97]It is clear from this summary of a detailed report that a key feature in this case is the ‘lack of a shared understanding’ of what led the defendant to kill his wife. This is a barrier to progress on core risk reduction areas. In Leigh’s oral evidence to the panel, she began by observing that she had seen a different side to the defendant during the continuation of his evidence that morning (29 January) which she had watched on the video link. She said, “I'm observing... that if Mr Razzell feels criticised, or not believed, or slighted in ways, then that's something he has difficulty with and, linking with what the senior psychologist said about that, makes it less able for him to be vulnerable… there some of the things that I've been seeing as Mr Razzell has given evidence.”[98]She had spent some time with the defendant, but he had made no acknowledgement of IPV and not shown any ‘chink’ that he might have emotionally abuse Linda. He didn’t see using family savings to take his secretary on a holiday as emotionally or financially abusive. He struggles with empathy for her and for their children and he insists that the risk factors which have been frequently identified in his case are not risk factors at all.[99]She was clear about the value of the OPD work but equally clear that it does not reduce risk although it was important in terms of risk management. When asked for two or three outstanding treatment targets that she was most concerned about she said they would be the ability to deceive and impression manage, controlling behaviour and understanding, expressing emotion of self but also recognising in others.[100]She agreed with the panel that continuing to look for Linda would be problematic and would significantly harm the secondary victims in the case. She qualified the suggestion that age would be a protective factor and said that in GR’s case it is hard to say whether it is or not. Consistent with the defendant's history of ‘ruptures’ with some professionals she considered that if the community offender manager changed and was replaced with someone more authoritarian that would cause problems because only a particular kind of supervisor, someone warm and therapeutic, would work with the defendant for an optimum outcome.[101]When asked about the question of maintaining innocence being protective against the risk he poses, she told the panel that it's protective for him, but the relationship with risk is quite complicated and it's hard to work out the function of it. She drew the attention of the panel to the SARA risk assessment [noted above] and she said that from the perspective of his disordered thinking which links to insight it is considered a risk factor and is relevant to the risk of future offending. So, ultimately her view was that the maintenance of innocence in this defendant's case was actually going to be a risk factor rather than reducing risk.[102]The psychologist it said that it was difficult, but her recommendation was that the risk the defendant posed could be managed in the community although there are gaps in understanding his risk and a focus on robust external controls. Core unmet needs remained. They could be delivered in the community or in custody in open conditions, but what she called “the trickiness” is about the defendant’s willingness to engage meaningfully. When the judge tested her view that the defendant poses a moderate risk but with low imminence, by asking how, if she did not understand why he did what he did and what the trigger was, she could say what the imminence of it is, she agreed it was possibly difficult to do so.[103]In response to questions from Mr. Jones KC for the Secretary of State she explained that the robust external controls would be a multitude of things including psychologically informed work overseen by the OPD pathway which would be delivered by offender managers and key workers. She was confident such provision would be available although she accepted that it was not [and could not be] expressly included in any licence condition. She agreed that a lack of shared understanding of the risk factors reduced her confidence that he would meaningfully engage to address them but there had been a shift in terms of an acknowledgment of whether the vulnerabilities he has, which he had not previously seen as vulnerabilities. When asked about her use of the word disparaging to describe the way the defendant had described some of the risk reduction work that had been attempted with him in the past she said that what concerned her as a psychologist was that when assessing change from an intervention that has been gone through in the past, she would expect the individual to be able to say what they had gained from it such as being able to describe their schemers or unhelpful modes, but that was not something that the defendant did either to her or when he was giving evidence to the panel.[104]Next she was asked about the function of denial in GR’s case. She was not entirely sure what the function was and that did reduce her confidence in whether he has and will engage meaningfully. She was asked about dishonesty and deception and its impact on her assessment. Her view was that it's difficult to answer the question but from the perspective of risk assessment she would think how would risk management be affected if he had told the truth or if he had lied and did not engage meaningfully with the work that is supervisor required.[105]Fran Rawlings had known the defendant as his COM since April 2025 and strongly supported release. She had discussed a detailed MAPPA framework which was the product of the Major Crime Team, representatives from three Probation areas, prison and local authority staff and was at the highest level 3 provision, and the proposed licence conditions with him. She said that he had resigned himself to never being released but despite that it was to his credit that he had joined with the work done by Overton with “openness and transparency”. “My view is based upon my involvement in Mr Razzell’s psychology ‘life line’ work has been during the sessions there appears to have been a notable shift in his willingness to drop barriers. In more recent sessions [eg] When Ms Overton altered her approach, in action, and deviated from the usual style of session that evidently (from his body language) threw him off guard, but he went with the flow and engaged well. I believe we did start to observe a more authentic side of him. This has been a positive shift from prior reports in regards to Mr Razzell’s engagement whereby eliciting therapeutic alliance amongst professionals has appeared to present with difficulties and Mr Razzell’s rigidity and lack of receptiveness to psychologically progress has been a pattern of behaviour observed. …He did acknowledge or at least offered the perception of him he feels amongst professionals is, he is ‘difficult’ and ‘would make lots of notes’. Mr Razzell promoted this has been a result of a chronic mistrust of professionals in his past and has felt the need to protect himself. Whether this is a skewed perception or a potential manipulation tactic (during sessions with the life map work), what I have observed is a noticeable shift in his willingness to listen and reflect, (comparing against the backdrop of previous reports) and be more relaxed in sharing his anxieties and difficult emotions. At these times it has not appeared disingenuous. … In terms of developing flexible thinking and perspective taking – Mr Razzell seems to have shown development insight when it comes to perspective thinking and being flexible. The motivation for this, I view in part, may be born out of ‘tiredness’ he has described feeling drained or words to that effect. Consequently, less inclined to try and maintain his own narrative. However, as suggested above there has been some observable shifts in his demeanour and willingness to engage far more collaboratively. …if released I would suggest a carefully managed transition of professionals involved with input from HMP to community OPD. Building upon the progress observed and utilising strength-based approaches to the delivery of toolkits for example ‘Skills for Relationships’, that could continue developing and exploring work around attitudes, behaviours and interactions within relationships both intimate and non-intimate. I have contacted OPD services in Ipswich and they have agreed in supporting a case consult inviting all current professionals involved, this is in its infancy but is designed to be proactive in the event Mr Razzell were to receive a future release decision... There remains a considered presence of distorted thinking about intimate partner violence based on Mr Razzell’s ongoing denials and his persistent focus on attempts on proving his innocence, that has included attempts to discredit and blame the victim and others… [Helen’s Law] …It remains evident that Mr Razzell’s position remains unchanged, However, as discussed, I view we have more recently seen observable evidence of improved collaborative working relationships with professionals and an increased willingness to be less rigid and more accepting of risk measures and an understanding of reasons for them, based on his conviction. There is also demonstrative evidence since 2017 and a move to open conditions that he has been transparent and will comply with risk measures in place to protect victims. There is no evidence or intelligence to indicate he has commenced a new relationship or acted inappropriately in this regard.”[106]Although she recognised the need for continued evaluation of the defendant and robust responsivity to any changes in potential risk, and that possible manipulation and deflections existed in the context of denial of the murder, she was confident that the sustained period of testing in open conditions, supplemented now by his improved interactions with the professionals including herself, supported GR’s likely compliance with the RMP.[107]In her oral evidence she expressed the view that she would be able to notice if the defendant presented in any way differently to her experience. If he became obstructive or difficult she would escalate the situation. She was likely to be responsible for his case for a minimum of six months before a transfer to another COM would be agreed at a senior level. After 12 months the defender would not be living at an approved premises and he would not be required to maintain GPS tagging beyond that period either. She agreed that at that stage there would be something of a “void”. She was asked by Mr. Jones if he entered into a relationship after the first 12 months on parole and didn't tell her or another capital COM how would they know and she said that it would be through noticing changes in him and perhaps if there was a home visit at the point of a change or if his phone was looked at. But ultimately she agreed that if he to maintain his demeanour in interaction with the new capital COM I didn't use his phone there wouldn't be any way for the capital COM to find out about the relationship. It is not possible for the panel to mandate OPD provision as a licence condition, and in that respect the licence conditions remain somewhat generic albeit at a high level, comparatively. The defendant’s evidence to the Board[108]The defendant said he has an open mind as to where his wife is and he had been searching quietly online, spending thousands of hours when he was in his flat. If he was released he would carry on doing so, in his own time. He hoped that the impact of the loss of their mother on his children had reduced with time now that they were older although he did read the victim impact statements they provided. He accepted that Linda had completely disappeared and believed she had conspired with someone else to put her blood in the car he was using on the day she was last seen, in order to make him look guilty. He explained her abandonment of the children he agreed she had loved, by referring to her not being well mentally.[109]He was asked to describe the ongoing impact on his children of not knowing where their mother’s remains were and he said he hoped it would diminish with time and making a false confession would probably be more harmful as he would not be able to say where the remains were.[110]He had about £170,000 of equity in his flat and £30,000 in savings. He admitted he'd had problems with previous COMs who he found to be ‘a nightmare’ but he had a good relationship with his current COM who was very professional. He was asked what he thought the main risk factors would be if he were to be released and he said, “I think the risk is that I can't find a way of living. I don't know how I'm going to live. I don't know what my daily, weekly routine is like and I don't have a release, finish. I don't know what my life will look like on leaving the AP. I don't know what I'm going to do, how I'm going to fill my time. So that's a big unknown… I had an aspiration to take up sailing but, again, I'm not steady enough on my feet now to start doing that. So, I don't know, and I think the risk, so I don't think there's a risk that I'll go out and murder anyone, but there's a risk that I won't be able to find a fulfilling, purposeful life... I think I may become just emotionally happy. I don't know. It worries me… I don't really want another relationship. I think I'm too damaged for that”[111]He had not met any women during his periods of leave on ROTL etc for more than a passing conversation. He was taken through the list of conditions proposed for the licence, were he to be released and he said he would comply with them though some of them were a nuisance.[112]In his written representations for the hearing he had included, “4. Maintained innocence is an additional protective factor.” He explained that he understood that there has been research into recidivism by people who maintain innocence and they have a lower rate of re-conviction than those who make admissions. He maintained his innocence of the unproven allegations and when it was put to him that the fact he went on to murder his wife after he had (as the panel had by then found,) committed that violence towards her, meant that there was no protective element to his protestation of innocence of the murder, his response was that he didn’t go on to murder Linda.[113]He was asked about Emsden’s formulation of the risks he posed and the interventions or work that would help to gain clarity about triggers or warning signs about them. He said, “I just don't agree with her opinions…I don't have risk behaviour relating to intimate relationships. I accept that I'll have to do work and continued work and it makes my management more difficult because no one understands why... I mean the fact is I didn't kill my wife so there isn't a trigger or behaviour behind it.”[114]He was challenged about his failure as noted by the previous panel, to follow through on the work needed after sessions such as check-in sheets and the fact that it had been recorded that he hadn’t done that work because he wasn’t encouraged to, he didn’t take the initiative because of laziness, and he had seen no value in them, saying, “They are not sufficiently worthwhile to waste my precious time.” His response was that he didn’t remember that and he would not have been so dismissive to the panel, his responses must have been recorded wrongly.[115]When taken back to para 7.56 of Emsden’s 2020 report [47] above, he said he recognised the list. He was asked which of those he still needed work on. The defendant said that he would need to work on the list together with the people managing him because he wants them to understand how he thinks and to understand “the expectations, the rigidity, difficulties, unwillingness, a lot of this, I think is because of the situation I find myself in.” In the past he had been at loggerheads with the people who were supervising him, “in a similar way I've been at loggerheads with some of the panel members questioning me today”. He thought that was because of the way he can come across and so he may be perceived as being rigid, entitled, inflexible in his thinking and unwilling to compromise but that was more perception of others than the reality.[116]He had found the schema work interesting, and he thought it had been largely done albeit not necessarily communicated to the people managing him. He could not elaborate. He agreed that he had still got work to do on the area of identifying and recognising emotions. He said his view had changed from 2020 or 2021 when he was first presented with Emsden’s list. He hadn't recognised 7 or 8 bullet points as things he needed to work on but particularly after the work he'd done with the senior forensic psychologist he had a new perspective. But when pressed as to what his new perspective was on (as one example), identifying and recognising emotions he said, “I think the perception has been that I didn't feel some of the emotions, and I think that was a wrong perception, but I think that it has affected the way that people interact with me.”[117]The panel pointed out that this was GR going back to other people's perceptions rather than accepting that he needed to work on this topic. He was then asked about understanding the emotions of others and whether he accepted it was something that he needed to work on and if so why. He responded that he appreciated that, but in the past he had made people cross who were trying to supervise him but he'd learnt the lesson that he needed to be more aware of other people and their emotions. He did agree that he could work on exploring self-esteem whereas four years ago he had rejected it outright, he was now much more open to it. And he also agreed that he needed to work on IPV related factors. This plainly surprised the panel. When he was asked to summarise his reasons, given he hadn't previously recognised this as a problem, his response was less promising, “So, I don't have any IPV, despite what everyone is saying. You know, my attitudes to women, I think, you know my generation has got, you know, different, we were brought up differently to, you know, to my children. But, certainly, my children were brought up to be, you know, to not have the same rigid views that my generation, perhaps, my parents’ generation had. I don't think I've experienced sexual jealousy... I certainly could have been more sympathetic to Linda in the months and years before we separated... but by 1998… our relationship was in trouble … and as I've said before I could have done much more in, certainly the year before that, to put our marriage back on track that I didn't do... Whilst I haven't committed IPV, I think I could benefit from work on my insight in that area.”[118]Overall, the defendant stuck to his long-standing position that there is nothing in his personality or past behaviour that should give rise to any fear of harm from him. The work done over sessions with Lucy Overton had enabled him to build better relationships with prison and probation staff but crucially, he was not moved on whether even the findings of the panel on IPV prior to his wife’s disappearance could give rise to deeper engagement with Offending Behaviour Programme and other Interventions which, according to the Interventions Guidance, are aimed at “2.1…changing the thinking, attitudes and behaviours which are associated with offending. Some are aimed at a specific offence type, and others address multiple types of offending. 2.2 OBPs and Interventions encourage pro-social attitudes and goal setting for the future and aim to provide prisoners with new skills to reduce their likelihood of reoffending. Many have traditionally used cognitive behavioural techniques and focused on issues such as problem solving, perspective taking, managing relationships and self-management. 2.3 The most recent interventions build on this but take a strengths-based approach. This approach focuses on the capacity, skills, knowledge and potential of the individual whilst ensuring that the management of risk is key. Practitioners work collaboratively with prisoners to help them to bring about change themselves rather than having it taught or imposed upon them. The quality of the relationship between the prisoner and the practitioner is key. Programmes which take this approach can be seen to be more inclusive by seeking to respond to a range of issues often experienced by prisoners which have in the past sometimes been a barrier to their progression - including difficulties with engagement, difficulties forming and maintaining therapeutic and professional working relationships and maintaining innocence. HMPPS now use this approach with interventions for men convicted of both violent and sexual offences.” The Parole Board’s decision[119]The Parole Board directed release accepting that GR murdered Linda, that the murder involved “instrumental violence, significant planning and boundless deception”, and that he continued to deny guilt and to withhold information about the location of her remains. It held that the defendant’s refusal to disclose the remains engaged Helen’s Law and bore on risk because it indicated poor insight, a desire to control the narrative, callousness, self-centredness, lack of empathy, and deficits in internal controls in the context of future relationships.[120]The panel’s release conclusion rested on the view that the identifiable risk was in the context of relationships, that the risk was significant/not trivial but not imminent, and that GR had demonstrated compliance in open conditions and on extensive ROTL/community exposure. It acknowledged serious doubts about his honesty and willingness to comply but concluded that his motivation not to return to custody, the understanding of his supervisors, and the proposed risk management plan were sufficient to bring the case within the statutory test.[121]In a little more detail, the Board treated Overton’s evidence, rightly, as engagement and relational progress, not as evidence of completed risk-reduction work. Her work with GR comprised therapeutic engagement sessions, “not designed to be an intervention” and that she did not “complete or comment directly on risk reduction work”. Overton had seen a more open, more vulnerable and less professionally guarded side of GR than the panel itself saw in the hearing. It recorded her evidence that he had developed greater trust, was more reflective, had shown vulnerability, and some ability to go away and think about matters when challenged. However, the panel recognised this was not criminogenic risk reduction in the strict sense. It expressly recorded that Overton said she could not properly comment on whether what she had observed had reduced risk, and that she agreed with the panel’s suspicion that, remarkably, during the hearing itself GR was trying to control the panel.[122]The Board treated Leigh’s report and her oral evidence as the main psychological risk evidence. It described her view as “well-informed and well-judged” where she said that, on balance, risk could be “closely monitored and supervised with intervention in the community” if GR meaningfully engaged. At the same time, the panel carefully recorded limitations and caveats in Leigh’s evidence. She recognised IPV-related risk, the need for immediate disclosure of any intimate or non-intimate relationship, the importance of victim safety planning, and the need for long-term implementation of risk-management strategies. She also identified gaps in understanding, lack of insight, unmet needs, reliance on external controls, and the need to develop internal controls.[123]The Board recorded that GR did not accept the identified risk factors as present or relevant. It also noted Leigh’s view that denial of the killing made risk assessment harder, reduced confidence, and prevented collaboration on risk factors. In her oral evidence, Leigh acknowledged that GR was “devious and manipulative” and that he “could be saying dishonestly that he will engage meaningfully”. The Board relied heavily on Leigh for the proposition that release could be managed, but in my judgment her evidence was not unqualified. It was conditional, nuanced, and repeatedly recognised limitations tied to meaningful engagement.[124]Rawlings, the COM’s, evidence was strongly supportive of release. She described a “demonstrable shift” in GR’s willingness to undertake work, and considered that his relationship with professionals had become more positive. She relied on lengthy testing in open conditions, adherence to ROTL/licence-type controls, and improved interactions with professionals. She referred to an exceptionally large number of days and overnight stays in the community. The Board saw important qualifications in Rawlings’ evidence, however. She accepted there were “absolute limits” to GR’s understanding of risk, that renewed OPD involvement could not be mandated as part of the licence conditions on parole, and that if he started a relationship and concealed it, supervisors could not find out. Nonetheless she had no indications that he had been in relationships or would not disclose a relationship.[125]The Board treated Jouhki, the POM, as another supportive professional witness, but it did not accept her evidence uncritically. She described GR as more relaxed, more open, more emotional, and genuinely interested in working with her, the COM and the psychologist. GR had let down his guard, somewhat. He remained persistent in his theories but she thought he would be forthcoming with relevant disclosures about relationships; despite not believing he posed a risk. The Board expressed some reservations and scepticism about Jouhki’s interpretation. When she said she did not think GR was trying to control the narrative in appointments, the panel said it was “not confident” that she was right. The panel also recorded her acceptance that he had done no rehabilitation work on domestic violence or murder, although she believed there was no core work left outstanding.[126]The panel’s assessment of GR’s own evidence was markedly adverse on credibility, insight and honesty. The Board found that the murder showed careful planning, concealment of remains, “boundless deception”, and an ability deliberately to hide the truth. It considered his continuing suggestion that Linda might still be alive callousness and a concern to maintain “a false image of innocence” and his status as a victim of a miscarriage of justice. The panel repeatedly rejected or doubted his explanations. It considered Linda’s witness statements significantly more dependable than his accounts and described his evidence generally as “self-serving and unreliable”. In relation to his dismissal from a prison driving role in 2024 when he had been caught changing rotas etc without authority, it noted variations in his explanations and described his initial claim that he had not been dismissed as an attempt to control history.[127]The Board found that GR had a dominant need to control situations, an intense focus on minutiae, and a tendency to blame and demean Linda. His continued denial meant he had not undertaken treatment, education or training to reduce risk and had not demonstrated, and might not possess, insight into what led to his offence. Although the Board found him unreliable and lacking insight, it did not treat denial or lack of insight as a bar to release but as important risk factors.[128]The key paragraphs of the panel’s conclusion are “4.4. The effect of Glyn Razzell’s denial of his offence that most directly affects his position with regard to release on licence is that he has not undertaken any treatment, education or training to reduce his risk to the public. Furthermore, he has not demonstrated, and may well not possess, any insight into what led to his offence. 4.5. The panel’s findings of fact with regard to the allegations (see Section 1 above) lead to the conclusion that Glyn Razzell killed Linda as the culmination of a series of incidents of intimate partner violence founded on his desire to control his wife and anger when he failed to do so. This lends support to the approach taken by those working with Glyn Razzell over many years, and by previous panels of the Parole Board: that, notwithstanding his lack of insight and the lack of understanding of his offending that follow from his denial, the risk he presents can reasonably be understood in the context of intimate partner relationships and does not raise wider concerns. 4.6. It is in that context that the panel considers whether Glyn Razzell passes the test for release set out above. 4.7. The Secretary of State points out that the panel’s acceptance of the truth of the allegations reveals what Glyn Razzell is capable of, his lack of insight, and his rigid thinking and disregard for the impact of his stance on Linda’s family. It also undermines the suggestion that ‘maintained innocence’ could be a relevant factor in this case: he denied the earlier IPV and still went on to demonstrates a risk to the public by continuing to inflict harm on Linda’s family; by not completing any risk reduction work; by the lack of any assurance that he will do any work on internal controls following release. The Secretary of State argues that the external controls included in the Risk Management Plan do not fill the gap left by the lack of internal controls. In particular, insofar as the external controls depend on Glyn Razzell being honest about, for example, relationships, he has demonstrated his dishonesty (as discussed above), as well as the careful planning that must have preceded the murder. 4.8. In his closing submissions Glyn Razzell points out that, since he is not currently in a relationship, any risk of intimate partner violence he presents cannot be regarded as imminent. He describes that risk as extinct, not, as has apparently been said elsewhere, dormant. He expresses sorrow for the effect his activities in pursuing his claim of innocence have had on his children. The panel has said above what it thinks of such expressions of regret. He continues to argue that what would make a difference to the children is knowing what happened to Linda, and that is why he proposes to continue his inquiries. The panel is bound to comment that, he having been convicted of the murder, it must follow that he has no need to make any inquiries. 4.9. Remarkably, in his Closing Submission, Glyn Razzell seeks to put part of the blame for the recent increase in media interest, and therefore distress to the family, on the family itself, for seeking a public hearing. 4.10. It is apparent from all of the above that the panel is unconvinced (to say the least) by much of what Glyn Razzell says about himself. However, the salient features of this difficult case remain. He has demonstrated during his sentence, and particularly since 2017 when he has been in open conditions and spent a lot of time unsupervised in the community, that he can comply with controls placed upon him for the protection of the public. The only identifiable risk he presents (and it is plainly a very significant one) is within the context of relationships and is therefore not imminent. The Risk Management Plan, combined with the understanding his supervisors have of him and his desire not to return to prison, is sufficient to manage that risk. 4.11. The panel considers that, notwithstanding the serious doubts there must be about Glyn Razzell’s honesty and his willingness to comply with any licence conditions, because he expresses the view that none of them are necessary, he will comply with licence conditions. He is strongly motivated not to return to custody. He has a place to live already established. He has an income on which he should be able to live without financial problems. There is family support, although the panel agrees with the Secretary of State that the fact that at least part of his support network believes in his innocence reduces its value as a protective factor. One of the strong protective factors the panel finds, perhaps counterintuitively, is Glyn Razzell’s deep desire to control the narrative and maintain the façade of his innocence. As he pointed out, any return to offence-paralleling behaviour would demonstrate, even to those who currently believe his version of events, that the jury’s verdict was correct. His improved relationship with his Community Offender Manager, although based, perhaps, on her approach to supervising him being better informed, rather than on Glyn Razzell having changed his attitude to being supervised at all, gives further confidence about his behaviour in the community. 4.12. The panel considers that Glyn Razzell passes the test for release. The panel turns to the proposed licence conditions…”[129]It is apparent that the Board’s reasoning moved through four stages.(i) It identified the risk factors adopting the previous panel’s risk-factor analysis. It considered that the main risk behaviour related to intimate relationships and any associated children, with the risk to his adult children being continuing psychological harm from denial and failure to locate the remains rather than physical violence towards them.(ii) Next, the Board identified protective factors including those identified by previous panels: detailed release plans, family support, move-on accommodation, compliance with licence conditions, desire not to return to custody, and “counterintuitively”, his wish to establish innocence or not be seen as a bad person. It also placed significant weight on the “stark fact” that he had been in open conditions for almost nine years and had spent a remarkable amount of time in the community, unsupervised, without problems.[130](iii) Then it asked whether risk was manageable despite unresolved internal risks. Acknowledging that concerns remained and GR had not undertaken offence-focused work on murder or domestic violence, and that his denial meant he had not demonstrated insight into what led to the offence, the panel recognised his improved engagement with professionals and the Board treated the RMP as “undoubtedly robust”. It included approved premises, relationship disclosure, electronic monitoring, controls on phones/internet/dating sites, media restrictions, non-contact conditions, and exclusion zones. It expressly recognised that some measures would only operate for a limited period, but accepted nonetheless the professional witnesses’ view that if GR complied and did not evade controls, he could safely be managed.[131]Finally, (iv) it reached the conclusion that denial and Helen’s Law were not a bar to release if the release criteria were otherwise met. It accepted that the damage caused to the family was incalculable and that GR demonstrated hypocrisy and heartlessness by continuing in his denials but held that the family’s argument that withholding the remains continued to offend by preventing lawful burial did not add to the risk to the public which the panel had to consider. The decisive reasoning appears to have been that the identifiable future risk was significant but confined to relationships and therefore not imminent. The panel concluded that his time in open conditions showed that he could comply with controls placed upon him for public protection, and that the risk management plan, supervisors’ understanding of him, and his desire not to return to prison were sufficient to manage the risk.[132]The panel acknowledged “serious doubts” about GR’s honesty and his willingness to comply because he viewed no conditions as necessary, but nonetheless concluded that he would comply, as he had said he would. It follows that the decision strongly documents the evidence against GR: the murder, concealment of remains, adverse Helen’s Law findings, proven domestic abuse/control allegations, absence of offence-focused work, poor insight, and significant concerns about honesty and manipulation. Its reasoning is also clear in identifying the professional consensus that release could be managed, subject to engagement, disclosure, monitoring and a robust RMP.[133]However, to resolve the tension between these the panel moves from “the risk he poses can be managed if he complies” to satisfaction of the test that there is no more than a minimal risk of serious harmful offending, without explaining why and how it overcame its own serious doubts on the limited evidence of the defendant’s own undertakings. The Board treated his long record of open-conditions compliance, community exposure, improved professional engagement and desire to avoid recall as sufficient to satisfy the test. Its own adverse factual findings and concern at lack of insight did not preclude release because the risk was assessed as specific, not imminent, and externally manageable. The conclusion on the statutory test therefore depended less on internal rehabilitation than on external controls, professional monitoring, and past compliance in the open estate. The Referral[134]The SSSJ’s reasons for referral can be distilled into three principal criticisms of the Parole Board’s release decision, all directed to the statutory question whether the court can be satisfied that it is no longer necessary for the protection of the public that GR remain confined. 1. The defendant has undertaken no meaningful risk reduction work[135]The SSJ contends that GR’s continuing denial of murdering his wife and his continuing refusal to disclose the location of her remains have prevented him from developing insight into his offending behaviour. As a result, he has never meaningfully addressed the risk factors thought to have led to the offence. The referral emphasises that: 1. Mr Razzell still denies the murder and denies previous domestic abuse. 2. Because he denies the offence, he has been unable or unwilling to explore the triggers for his behaviour, his attitudes to intimate partner violence, emotional functioning, control, entitlement, and relationship difficulties. 3. The work undertaken with Overton was expressly described by the professionals as not risk reduction work and not an offending-behaviour intervention. 4. The Parole Board itself accepted that he had not undertaken treatment, education or training to reduce his risk and might not possess any real insight into the causes of his offending.[136]The SSJ therefore argues that the Board released a prisoner who remains fundamentally unrehabilitated in respect of the core factors associated with the index offence. 2. The release decision improperly assumes that risk reduction work can occur after release[137]The second and central submission is that the Board's decision rests on the expectation that GR will undertake important rehabilitative work in the community after release, despite not having completed it in custody. The SSJ identifies four concerns:(a) Work should be completed before release. If important risk-reduction work remains outstanding, public protection requires it to be completed while the prisoner remains confined rather than after he is released into the community.(b) Lack of clarity. There was no clearly defined programme capable of demonstrating how the remaining risks would be reduced. The Board was effectively being asked to assume that a future programme would be devised and would succeed. Alternatively, it would fail and he would be returned to custody, but the risk persisted in the meantime.(c) No confidence he will engage. GR has a long history of going through the motions of compliance while resisting the substance of intervention. The SSJ argues that his participation in the Overton sessions does not demonstrate willingness to undertake the much more difficult work that remains outstanding.(d) Difficulties of assessing "meaningful engagement". Even if community-based work were imposed, it would be difficult to determine whether GR was truly engaging or merely appearing cooperative while making little genuine progress.[138]The SSJ submits that the Board effectively released him in the hope that rehabilitation would take place later, and the risk he poses would be ‘managed’ in the meantime, rather than because rehabilitation had already reduced risk to an acceptable level and the public could be protected from the residual risk by the licence conditions. 3. The Board placed excessive reliance on compliance and external controls despite repeated findings of dishonesty[139]This is perhaps the strongest practical criticism advanced in the referral. The SSJ argues that the Risk Management Plan can only work if GR is honest with those supervising him, yet the Board simultaneously made repeated findings that he is dishonest, manipulative, deceptive and determined to control the narrative. 1. The referral stresses that he continues to deny the murder and concealment of the victim's remains. 2. The Board found him capable of "boundless deception" and noted continuing concerns about dishonesty and impression management. During the parole process he was found to have given misleading accounts concerning his dismissal from a particular prison employment. 3. The COM accepted that if he entered into a new relationship and concealed it, supervisors might never discover it. 4. The principal risk identified by the Board was the risk of IPV in the context of future relationships. However: supervision depends on him disclosing relationships; there is little confidence that he would do so honestly; many external controls are temporary; after the initial period much of risk management depends on self-reporting.[140]Accordingly, the referral contends that it is irrational to regard a risk management regime founded on honesty as sufficient when the Board made repeated findings that the prisoner is habitually dishonest.[141]The SSJ's essential submission is that the Parole Board accepted four propositions simultaneously, the last of which cannot comfortably coexist with the others: he continues to deny any domestic abuse and the murder, he has failed to undertake meaningful risk reduction work so there is no insight into his offending, there are serious doubts about his honesty and willingness genuinely to comply with supervision, and the future management of risk depends upon his honest compliance and his undertaking rehabilitative work after release. If this be right, the court cannot be satisfied that confinement is no longer necessary for public protection, particularly regarding any future intimate partner and the continuing psychological harm to Mr Razzell's children arising from his refusal to disclose the victim's whereabouts.[142]Mr Jones KC developed these through five core submissions: 1. The starting point for a consideration of the public protection test must be that this defendant is a deeply deceitful individual who carried out a campaign of violence against his wife, some of it witnessed by his children. Having been twice acquitted by juries, he went on to murder her. 2. The fact that many of the reports on GR emphasise the uncertainties in his case, the gaps in understanding him which mean there are significant gaps in being able to make provision for the future, is critical when assessing risk. 3. He has not completed the risk reduction work identified as being necessary. Although weight was placed in the January 2026 hearing and subsequent decision on the co-operation he gave in his recent sessions with Overton, that was not risk-reduction work and the progress made was extremely modest. He only complied because those participating created a ‘safe space’ for him and his honesty and transparency there was not about the key issues concerned with risk, such as his capacity for violence and murder. 4. GR continues to cause harm to the victims. As well as continued denial, he took part in a two-part documentary investigating his claim of being the victim of a miscarriage of justice (although it seems the producers found no flaw in the conviction), there is a website expressing the same attitude of denial and he continues to blame his wife for his position and says he will continue to ‘search’ for her. 5. The licence conditions settled on by the Parole Board in its decision of 12 April 2026 cannot fully address the risk. There is a world of difference between short periods on release, however frequent they are, and living in the community. The risk will surely manifest, if not earlier, in 18 months or 2 years when licence conditions have fallen away and GR is living in the community and encountering all kinds of people including vulnerable women.[143]Mr Jones says Helen’s Law bites in two respects. GR’s denial of responsibility has made risk reduction work difficult, though he concedes this may be likely in all such cases. Although he does not argue that maintaining innocence will prevent progressing in any risk reduction work, the progress in this case has been extremely limited because GR simply does not accept he is at risk of IPV at all, while and the same time it is central to the psychologist’s analysis in his case. Secondly, he is so attached to his narrative of innocence that he willingly continues to inflict pain on his victims, blaming Linda for leaving her family of her own volition, so he does not come before the court as someone who is doing all he can to avoid harm, which might be the position in other cases.[144]Mr Jones also identifies what he considers to be an important error in the Parole Board’s analysis albeit he was conscious that this is precisely not a judicial review of that decision. The topic is whether, as the Parole Board found, maintaining innocence was itself, albeit ‘counterintuitively’, a strongly protective factor militating against the risk. The evidence to the panel did not support that finding and the Board’s own findings in respect of the unproven allegations contradict the idea of it being protective: he was acquitted of harming Linda although the Board found the essential elements of the allegations largely proved, yet those acquittals did not act as a protective factor because he went on to murder her.[145]Finally, Mr Jones argued that the unproven allegations had to be considered afresh by this court which should not simply adopt the panel’s conclusions. Indeed, where the panel did not find an allegation made out, the court should decide for itself whether it was or not. The Response[146]The defendant's central argument is that the Parole Board correctly concluded, after hearing extensive evidence from professionals, that any remaining risk can be safely managed in the community. In reaching its own conclusion the court should attach considerable weight to the Board’s assessment, reject the suggestion implicit in the SSJ’s referral that denial of the murder is determinative of the statutory level of risk, give weight to the extensive evidence of compliance over the very significant period of time since conviction, and not lightly disregard the consensus among the professional witnesses that release is appropriate now and that residual risk can be managed while on life-licence. 1. The Court should attach considerable weight to the Parole Board's assessment[147]GR emphasises that the Parole Board heard oral evidence directly; the panel was experienced and is specialist in risk assessment so the High Court should be slow to depart from its assessment absent cogent reasons. The Parole Board has unrivalled expertise in risk assessment. Its conclusions are therefore said to deserve substantial respect. Mr Stanbury also points out, accurately, that the panel was not naïve or credulous. There was a significant degree of testing of evidence and challenge, particularly to the defendant, some of which he found uncomfortable. I hope that the detail in which I have set out the panel’s hearing and decision demonstrates that I do respect their thorough work in this very difficult case. The task set out for me is to reach my own assessment on the evidence. Assessing risk is a rigorous evidence-based process which arises in many different contexts and judges are used to making such judgments.[2]Denial is not determinative of risk[148]The Defendant relies on the Prisoners Maintaining Innocence Guidance; (R) Raw v Parole Board [2021] EWHC 1943 and Oyston. In Raw Jacobs J summarised important principles, consistent with the guidance and indeed with Helen’s Law itself, to affirm that there is no presumption against release of a prisoner who denies guilt at [22] The Divisional Court in McCourt [R(McCourt) v Parole Board [2020] EWHC 2320 DC] reviewed prior authority, including many of the cases to which I was referred, and concluded that there was no such presumption. The following points, of importance to the arguments in the present case and consistent with the summary above, are clear from paragraphs [61] and [62] of McCourt:(1) The same legal test and approach was to be applied in every case. There is no special test applicable for particularly heinous offences.(2) The effect of the previous case law was that a “prisoner’s denial may well be a determinative consideration but not necessarily so”: [61], citing Gourlay, which was a case involving the transfer of a life prisoner to open conditions, rather than a release case.(3) Since a denial is not necessarily determinative, a very careful assessment has to be taken by the Board of all the competing factors in coming to a conclusion as to whether the risk had been sufficiently reduced.(4) In some cases, particularly in cases of serious, persistent violent or sexual crime where the denial makes it impossible properly to assess risk, the denial may in practice be determinative if and insofar as it prevents the Parole Board from properly assessing risk. The Divisional Court emphasised the word “persistent”.(5) However, in other cases, as in Oyston itself, there may be other evidence upon which the Parole Board can properly reach the conclusion that the prisoner presents a manageable risk of reoffending, notwithstanding any gap in understanding occasioned by the offender’s denial of the index offence.[149]The core proposition is that denial does not automatically equal risk but must be considered alongside all other evidence. Furthermore, in some cases it may even operate as a protective factor and GR specifically relies upon the Board's finding that his desire to maintain his claim of innocence creates a powerful incentive not to engage in future offending.[3]Extensive evidence demonstrates compliance[150]The defendant presses reliance upon over eight years in open conditions; compliance with more than 1,000 ROTLs providing very significant evidence of avoiding causing harm while on temporary release; compliance with prison rules; the development, since the last Parole Board hearing in 2023, of positive working relationships with supervising professionals. This is presented not as speculation but as real-world evidence that he can comply with controls placed upon him. The (highest) level 3 MAPPA provision that had been put in place shows that all that can be done is being done to protect the public and the defendant will have no doubt that any breach of their requirements will be likely to mean a return to custody.[4]All professional witnesses support release[151]GR highlights the unanimous professional evidence supporting release. Overton reported evidence of consistent engagement, openness, reflection, empathy, reduced resistance and increased vulnerability and insight. Leigh’s assessment was risk is not imminent, age is a mitigating factor, the protective factors are strong and close supervision in the community can manage remaining concerns and allow progress to continue. Rawlings considered that there had been a demonstrable shift in his attitude which together with his compliance history provided objective evidence supporting future compliance and meant the risk could be safely managed through a robust risk management plan. Jouhki concluded that the public protection requirements had been met because GR had engaged extensively with professionals. She was confident that he would comply with licence conditions not least because of his long history of compliance during his sentence.[5]Outstanding work is not a barrier to release[152]The defendant argues that the SSJ incorrectly treats outstanding work as a precondition of release. Relying on the Parole Board's Interventions Guidance, he submits that offending behaviour programmes are not a "cure" and risk reduction is a broader process. Significant OPD pathway work has already occurred, it was not easy for the defendant to do, and a clinical over-ride was necessary for it to be made available to him as he does not have a personality disorder. Further work can properly continue in the community. He argues that the professionals are not proposing release in the hope that risk reduction might happen later; rather they believe the release threshold has already been met, and risk can subsequently be further reduced.[153]Mr Stanbury for GR does not agree that I should interrogate the evidence of the unproven allegations. His argument was a combination of surrender to the fact that the allegations of IPV had been part of the defendant’s file for parole hearings since at least 2020 when Emsden produced her first report, and also that the findings of the Parole Board at the January 2026 hearing were almost inevitable given the weight of evidence available. Analysis and Conclusions The unproven allegations[154]I agree with the SSJ that all the evidence concerning previous incidents of IPV gain in probative force from the fact that GR went on to murder Linda. The SSJ identifies four recorded references to her fear that he would do exactly that in the panel’s dossier. “He said to me, “I’ll fucking murder you rather than let you divorce me” [p882]; “Glyn has also verbally threatened me that he would kill me rather than lose the kids” [p883]; “I saw his eyes which were wild – and they said to me “IM GONNA KILL YOU!” [p908]; “I am convinced that these incidents will escalate. I’m fearful that if Glyn is released he will return to my house regardless of any condition upon him preventing him from doing so - and finish what he was doing. I believe he wants to seriously injure me or my family” [p909-910].[155]The doctrine of res judicata does not apply and I am not bound by the panel’s evidential findings. I must decide any contested issue for myself but as a consequence of the parties’ positions, broad agreement, I do not need to repeat the panel’s detailed analysis of the evidence of GR’s prior abuse of his wife. The overall picture is clear, albeit my focus is on contemporaneous records such as statements from Linda and eyewitnesses rather than VPSs written with the benefit of hindsight (which Emsden and others also refer to). The material available is summarised in Ms Emsden’s 2020 report [with internal references] together with the defendant’s explanations to her some of which have already been included earlier in this judgment, see [47][156]Given the importance that the SSJ places on this material and the need for it to be assessed as it weighs on the question of future risk, it is appropriate to include some other accounts given by the defendant which are also conveniently captured in Emsden’s 2020 report. She incorporates, “6.10 Mr Razzell also discussed a further incident that was reported by others as IPV. He stated “Linda had been to her solicitors and she had no grounds for a divorce so we had to separate. I said, “I didn’t want to go, you’ll have to leave [the family home]”. She’d had a few temper tantrums before and had driven off with the wheels screeching. This time she ran to the neighbour who was a retired policeman and asked for help, the police were called. She said I’d kicked her and pushed her over and broke her rib. She did have a cracked rib which I think she probably did on the handle of the back door, it’s a bad design” [38]. There are a number of reports in witness, police and victim impact statement that indicate there were other incidence of violence perpetrated towards Mrs Razzell from Mr Razzell. In interview he stated that none of these were true. He highlighted that those people who knew himself and Mrs Razzell as a couple described him as one person, whereas those who knew Mrs Razzell individually described him as a different person (i.e. violent), he said the Police also commented there appeared “to be two Glyn Razzell’s” [38]. It should be noted that some of these statements are from family members who would have known them as a couple. .. 6.13 There were also reports of violence towards the children. Mr Razzell also disputes these. Other sources state:
“I asked what was the matter and Emma replied that Daddy had kicked Robin for taking his measuring tape. The violence in the home was not just directed at Linda” [8] Mr Razzell denies any allegations of harm towards the children. He explained that these incidents were always raised just prior to a court appearance, which he felt Mrs Razzell or her solicitor had planned. In relation to the incidents above he said he encouraged Robin to engage in DIY activities and as such would not have been annoyed at him having the tape measure. He also explained “Linda made an allegation I hurt Emma, pulled her wrist, it was a day out with Rachael, it was good for Linda for the divorce” [38]. He did acknowledge “the children saw the aftermath of the porch, there was a lot of blood pouring from my hand, and Linda needed stitches too (latter part said more quietly)” [38]. He recognised this might have caused the children psychological harm or emotional distress, although clearly stated this was not due to his actions [38].”
[157]The transcript of the 2026 hearing reveals a conspicuous adherence to the Guidance on Allegations (September 2023) The history of IPV was plainly relevant to the question of risk and in my judgment there was ample evidence to justify the conclusions the panel reached and which, with one exception, I adopt. They had GR’s most recent responses which are summarised earlier in this judgment. The only aspect they were unable to reach a firm conclusion on was Allegation 2. Both parties accept that a finding on this will have only a marginal impact however I am asked to consider it and I do.[158]Applying the Guidance and with respect to the panel, I would reach a different view. Taking account of all the material now available and bearing in mind GR’s evidence and his well-documented propensity to victim-blame Linda, I would find as a fact that Linda’s allegation (made in a statement on the day of the incident on 22 August 2000) was true on the balance of probabilities because I find her to have been a credible source, her actions and words at the relevant time were consistent with the allegation, indeed the defendant agreed in his evidence to the panel that Linda had run out of the house on that occasion, although he said she did so in case neighbours were watching (and presumably could be expected to provide supportive evidence.) Although she was engaged in a contentious divorce process the suggested motive she had to lie comes from an untrustworthy source and his presentation as the victim of a vindictive woman is inconsistent with the overall evidence of their relationship and GR’s behaviour towards his wife.[159]In my judgment the history of IPV with key features of coercive control provides the context for the murder, increasing its seriousness and gives firm confirmation that this defendant has a propensity to violence against women and that without some recognition of that aspect of his personality he remains a danger to women who come within his milieu. The impact of Helen’s Law[160]Parliament has required the decision-maker to take into account the fact that the victim's remains have not been recovered and any information which the prisoner has failed to disclose concerning their whereabouts or disposal. It is common ground that this statutory consideration arises in the present case. Helen's Law does not create a presumption against release. Nor does it establish a "no body, no parole" principle. Continued denial of guilt and continued non-disclosure are not automatic bars to release if the statutory public protection test is otherwise satisfied.[161]GR continues to deny responsibility for Linda’s disappearance, and he does not accept that he has information concerning the whereabouts of the victim's remains. He maintains that he cannot provide information because he does not possess it. I am satisfied that he continues to withhold information that he could deliver up. That is the first step. He also persists in stating that he is going to carry on ‘quietly’ looking for her when he can. I have taken account of the Board’s Disclosure of Information about Victims guidance. I have found that the reason for the non-disclosure is the defendant’s deliberate choice as part of his false claim of innocence. What are the consequences of this finding?[162]There are four relevant to my task in assessing risk. The first is that continued denial suggests an inability or unwillingness to appreciate the impact upon the other victims, Linda’s surviving relatives and others like Greg Worrall. The persistence of the narrative that Linda may still be alive demonstrates a striking absence of appreciation of the continuing harm caused to each of them despite the defendant having heard and read on at least four occasions now, powerful accounts of the continuing anguish they feel. This capacity to inflict repeated harm, albeit not serious harm to life or limb, especially on those who one has a duty to protect from harm, must be relevant when deciding if someone has reformed, feels remorse or, by contrast may still incline to harm others.[163]The next relevance is to do with lack of insight, what the psychologist Leigh called ‘a shared understanding’ of the crime. A critical question in a case like this is whether non-disclosure prevents understanding of offending behaviour. To reiterate, the significance of the non-disclosure is not punishment for maintaining innocence. The significance is that continued denial has prevented any meaningful exploration of the motivations, attitudes and behaviours which led to the index offence. This has an ineffable impact on preserved risk.[164]Thirdly, the question of honesty is at the heart of the assessment of risk here. The defendant has not engaged successfully in the core risk reduction work mandated by the experts from at least 2020. The panel accepted his commitment to be honest with his offender managers, and it is one of the central issues in the case. But he is a man who I find to be fundamentally dishonest. Accordingly, as the risk management plan depends upon compliance, disclosure, reporting relationships and transparent engagement with probation, confidence can I have that future disclosures will be made when GR has persisted in denying responsibility for conduct which a jury found proved more than 22 years ago? Again, the point that bites is impact on future risk management.[165]Finally, the control that the defendant exercises in keeping quiet is reflected in the types of harm demonstrated in the historic IPV and so, in this way too, his denial is relevant directly to the question of statutory risk. Indeed, he refused to acknowledge, even that he was violent towards his wife before March 2002. If he was able to do at least that it might assist him to engage in some of the core risk reduction work identified in his case.[166]Overall, the Parole Board material appears capable of supporting a finding that continued denial and continued promotion of the alternative narrative serve a function beyond simple maintenance of innocence. It is an unwillingness to relinquish ownership of the narrative, to accept oneself in a bad light and prioritisation of self-interest over victim impact. This is relevant to risk because it shows that GR is not a man who will lightly admit when things start to go wrong in his life, as they did with Linda. Given his failure to carry out any substantive risk reduction work he is, as far as internal controls go, the same man he was when he killed Linda, and that is relevant to risk.[167]Returning to Oyston it should be clear that I have not treated the fact that Linda Razzell's remains have not been recovered as an independent reason for continued confinement. Nor have I treated continued denial of responsibility as disqualifying from parole. Parliament has required those matters to be taken into account, and I have done so in the way I have set out. The heavy significance I attach to them in this case lies in what they reveal, or fail to reveal, about the prisoner's current level of insight, empathy, honesty, capacity for self-reflection and ability to engage with measures intended to manage risk. It is those matters, and their relevance to the statutory public protection test, which inform my conclusion.[168]I have regard to the view taken by the panel that the denial is such a strong part of the defendant’s persona now that it may act as some form of protection for the public. No doubt there are cases where this can be relied upon to some degree, particularly perhaps cases of sexual offending which carry special stigma, but even if the psychologist Leigh had maintained her position in evidence, and she did not, I would have considered it a speculative assessment. This is particularly after reading the detail of the Guidance on Prisoners who maintain their innocence and the study in the first footnote on page 8. Maintaining a denial is not inevitably risk-related see Raw, but for the reasons I have set out in this case I have come to the firm conclusion that it is. Application of s.28ZA Crime (Sentences) Act 1997[169]The Board’s decision in this case was, on its face, careful and detailed. The difficulty lies in the adequacy of its reasoning in reconciling the features adverse to the defendant with the statutory conclusion that it was no longer necessary for him to be confined. The critical question for the Court under s.32ZAC is not whether the Parole Board's decision was reasonable, but whether the Court is itself convinced that it is no longer necessary for the protection of the public that GR remain confined. The Court must be satisfied that there is no more than a minimal risk of further serious offending. The scrutiny required must be calibrated to the gravity of restricting liberty. Relevant statutory factors in this case include; 1. The nature and seriousness of the murder. It was a planned, cold-blooded killing which involved escalation of violence against a woman, the mother of his four children, who was divorcing him and who he had been coercively controlling (including financially) and physically assaulting. He killed her within weeks of being acquitted at the Crown Court of an assault against her ss.(5)(a). 2. The conduct of the prisoner while serving the sentence. An otherwise model prisoner who has never acknowledged responsibility for the murder, and who continues to withhold information about the victim's remains may provide a particular dilemma for the Parole Board and, on their own, denial and failure to disclose knowledge are not a bar to parole but conduct must be considered holistically. Fairly considered, the material also contains evidence supporting release, particularly the nearly nine years in open conditions, extensive periods in the community on release on temporary licence, generally compliant custodial behaviour, support for release from the COM and POM, a detailed and police level MAPPA licence package as well as Leigh’s psychological evidence that risk could potentially be managed in the community through intensive supervision ss.(5)(c). 3. The risk of further offending. The judgment of the psychologist is that this is at a moderate level, not trivial but it could be controlled further by external factors such as the licence conditions and MAPPA provision. In the context of controlling behaviour, deception and impression management, grievance thinking and emotional restriction and poor insight, the risk of further serious offending by GR remains insufficiently understood and insufficiently reduced. This is material because the professional consensus is that the risk in the future is most likely to arise in the context of a new intimate relationship. IPV is not easy to detect. The defendant is young enough to engage in such a relationship although he denies wanting to. If he were to do so his offender managers may not find out and be able to influence it ss(5)(d). 4. The risk of licence non-compliance. The proposed management strategy on parole assumes that the defendant will disclose any new relationship immediately; engage openly with probation and psychology services; report changes in his circumstances and comply with restrictive licence conditions. Yet the same material discloses historical dishonesty, impression management, narrative control and minimisation. Public protection cannot safely rest upon self-reporting by a prisoner whom the evidence repeatedly describes as capable of deception. The current relationships he enjoys with offender managers are not based on his ability and willingness to accept challenge from them. The prospect of false compliance and deceit must be high in a case such as this in which the latest psychological assessment states, "There are too many gaps, limits in shared understanding and this can impact on the efficacy of risk management strategies. At present there is a heavy reliance on external measures of control" ss.(5)(e). 5. The effectiveness of any treatment or risk reduction work; GR has done no effective work which admits his propensity to be violent in intimate relationships so he cannot be said to have reduced the risk factors associated with the offence, of repeated serious violence. Or shown remorse. It is not consistent with public safety to release a prisoner who poses more than a trivial risk of causing serious harm on the premise that he will engage on licence with the kind of relationship skills work that he has not been able to comply with in custody ss.(5)(f). 6. Helen's Law considerations regarding non-disclosure of the victim's remains, s.28A, are very significant in this case for the reasons I have dealt with in detail, above. Denial of the offence is present, but what is key in this case is denial of risk.[170]I am not persuaded that the risk has diminished to such a level that offender management is capable of keeping the public safe if the defendant is released. No one element is determinative and risk assessment is a difficult task. In GR’s case the identified risk factors, the relationship-based nature of the risk, concerns about control and impression management, denial and non-disclosure, demonstrable history of IPV and the Helen's Law considerations remained constant over the period from around 2020 to 2026 covered by the majority of the Parole Board dossier. Apart from longer served without error in open conditions (which is peripheral to IPV danger) the only thing that changed since 2023 was that GR did some psychological work, which it is important not to undervalue because it means those currently working with the defendant have a much deeper understanding of him than they would have had in earlier years. Furthermore, and usefully, GR has found professionals who he feels safe with. This was almost bespoke provision for a man who had refused to engage appropriately in what psychologists have told him is necessary.[171]But although the professional opinion to the Parole Board was unanimous in favour of release, it has been set out in some detail to show that it was not unequivocally expressed support and the release conclusion was vulnerable because the protective factors were largely external, conditional and dependent on honesty, whereas the risk factors were internal, persistent and directly connected to the index offence. The evidence of all the witnesses except Overton contained a degree of hopeful speculation. Questioning revealed flaws in their reasoning. The proposed release plan relies on trust that has not been earned and despite including MAPPA level 3 provision for at least the start of it, it underplays the significant gaps in GR’s understanding of the risk he poses. It is far from sufficient to persuade me that there is a secure foundation for the conclusion that confinement is no longer necessary for the protection of the public.[172]The defendant’s evidence was wholly unconvincing. In my judgment he is shrewd and cannot be relied on to comply honestly with licence requirements, especially when to do so might endanger his idea of himself as a victim, flawless and in control. A motivation not to return to custody may support compliance but it may also support concealment of conduct which he fears could led to recall. The COMs concession that if he begins a new relationship his supervisors may not find out, was telling. The concern is sharpened by evidence that some warning signs of increasing risk may not be observable and depend on self-reporting.[173]When the professional evidence with the limitations described, is coupled to the grave index offence, the history of IPV, absence of insight, the impact of Helen’s Law and the on-going harm being done to all the victims, the only safe decision is to refuse parole.[174]The matters I have identified do not mean that the defendant can never satisfy the statutory test. They do, however, indicate the nature of the evidence which would be required before a future decision-maker could properly be satisfied that continued confinement was no longer necessary for public protection. In particular, a future application would be strengthened by evidence that he has undertaken structured offence-related and relationship-focused work which directly addresses the risk factors identified in the psychological evidence; that he has moved beyond merely accepting that others perceive him as risky, to a genuine and testable understanding of why those risks arise; that he can identify in concrete terms his own warning signs, triggers, and patterns of thinking; and that he can demonstrate, through his conduct with professionals, an ability to be open where disclosure is adverse to his own interests. The evidence before this Court showed that his risk was understood primarily in the context of intimate relationships, that future relationships would have to be disclosed immediately, and that some warning signs might not be observable unless self-reported. It follows that a future case based on release would need to contain a much firmer evidential foundation for trusting his honesty and cooperation than existed before the Panel in January 2026.[175]In addition, a future application would need to confront directly the effect of Helen’s Law in this case. The relevance of Glyn Razzell’s continuing denial and non-disclosure is not punitive. It is evidential. The Secretary of State’s case, supported by material recorded in the Board’s decision, was that non-disclosure and denial had a direct bearing on insight, empathy, honesty, and the ability to engage in risk reduction work. A future application would therefore need to show that, whatever position Mr Razzell maintains about his conviction, he has engaged sufficiently with the risk implications of the Board’s factual findings, including the findings on the unproven allegations and the established pattern of controlling and violent behaviour towards Linda.[176]Finally, future progress would need to be demonstrable rather than asserted. Compliance in open conditions and on release on temporary licence will remain relevant, but the concern in this case was that such compliance did not answer the central risk of future relationship-based harm. The future evidence would therefore need to show that the defendant has developed internal controls and insight sufficient to reduce reliance on external controls, and that professionals can explain why any remaining risk is manageable without depending unduly on his unsupported self-report. That is the area where the evidence before the Panel was weakest: the proposed plan was robust in form, but its effectiveness depended substantially on candour, disclosure and meaningful engagement in circumstances where all three were open to serious doubt.[177]I thank counsel for their excellent submissions. Finally, I record that the powerful statements from the victims of this defendant’s crime described their suffering with remarkable moral clarity. The on-going agony of not being able to lay their beloved mother to rest and the regular pain of having to write down how they are coping with the hurt that invades so much of their lives, should have rung in the defendant’s ears. Perhaps it does. Like the Parole Board panel, I express my thanks to each of the writers; family members and friends.[178]I am not satisfied that it is no longer necessary for the protection of the public that Glyn Razzell be confined. Accordingly, I quash the Parole Board’s direction to release him on licence. Mrs Justice Cheema-Grubb DBE