McGrath, Application for Reconsideration [2025] PBRA 165 (12 August 2025) [2025] PBRA 165

PBRA
McGrath, Application for Reconsideration [2025] PBRA 165 (12 August 2025)
[2025] PBRA 165 · 2024-05-06
[1]This is an application by McGrath (‘the Applicant’) for reconsideration of a decision of a panel of the Parole Board (‘the Board’).[2]The Applicant is serving an extended determinate sentence (‘EDS’) for an offence of false imprisonment (‘the index offence’). The circumstances of that offence will be discussed below.[3]On 6 May 2024 the Applicant became eligible for early release on licence. His case was referred to the Board by the Secretary of State for Justice (‘the Respondent’) to decide whether he should be released early.[4]In a decision dated 13 August 2024, a panel of the Parole Board directed the Applicant’s early release. That decision was set aside for reasons discussed below, and a fresh hearing by a new panel was directed.[5]The fresh hearing by the current panel took place on 12 June 2025 and the panel decided not to direct the Applicant’s early release.[6]The Applicant’s solicitors have now applied on his behalf for reconsideration of that panel’s decision. The Application for Reconsideration[7]Rule 28(1) of the Parole Board Rules 2019 (as amended by the Parole Board (Amendment) Rules 2024) provides that in eligible cases applications for reconsideration of panel decisions may be made either by the prisoner or by the Respondent.[8]Rule 28(2) specifies the types of cases which are eligible for reconsideration. They include cases, like the present one, in which the prisoner is serving an EDS sentence.[9]A reconsideration application may be made on the ground(a) that the panel’s decision contained an error of law and/or(b) that it was irrational and/or(c) that it was procedurally unfair.[10]In this case the application for reconsideration of the panel’s decision has been made on the grounds of irrationality and procedural unfairness. No error of law is suggested.[11]The application was made within the time limit for applications of this kind and is therefore eligible for reconsideration.[12]I am one of the members of the Board who are authorised (as ‘Reconsideration Assessment Panels’) to make decisions on reconsideration applications, and this case has been allocated to me.[13]The documents which have been provided to me and which I have considered for the purposes of this application are:(a) the dossier of papers provided by the Respondent for the Board’s review of the Applicant’s case: the dossier now runs to page 670 and includes a copy of the panel’s decision;(b) the representations made by the Applicant’s solicitor in support of this application for reconsideration; and(c) an e-mail from the Public Protection Casework Section of the Ministry of Justice (“PPCS”) stating on behalf of the Respondent that she does not wish to make any representations in response to this application. Background and history of the case [In this decision when quoting passages from documents I have made slight adjustments to the wording, for example referring to the witnesses by their job titles and not by their names.][14]The Applicant is now aged 36. Before the index offence he had accumulated convictions for a number of offences including possession of cannabis, supplying heroin and crack cocaine and possession of a prohibited weapon (a disguised firearm).[15]The index offence occurred in October 2014. A brief summary of the offence is as follows: The victim was a female heroin user living in Hull. She had a substantial drug debt. She was taken to an address in Liverpool where she was kept and made to sell heroin. She was also subject to a number of assaults while she was held at the address. Various calls were made to the victim’s parents (who it was believed were in a position to repay the victim’s debt) demanding money and making threats of violence including a threat to break the victim’s fingers and toes. The police were made aware of what was happening and went to the address. The Applicant and his co-defendant were both present there and tried to escape out of a window.[16]The Applicant pleaded guilty to false imprisonment, blackmail, assault occasioning bodily harm and possession of cannabis. In addition to the EDS for the false imprisonment, he received concurrent determinate sentences for the other offences. The 2024 hearing[17]As noted above, on 13 August 2024 a panel of the Board directed the Applicant’s early release on licence. There had been an oral hearing on 27 June 2024 at the end of which the panel adjourned the case for further information. On receipt of that information the panel issued their decision on the papers (they did not think it necessary to hold a further hearing).[18]The panel noted that the Applicant’s behaviour in custody during his sentence had been far from perfect but although he had been abusive to staff on many occasions there had been no violence for 10 years. Reported instances of poor behaviour included kicking a bin in frustration and refusing drug tests.[19]The Applicant described in detail to the 2024 panel the frustrations of custodial life and said that he got frustrated by various things. Those included:(a) the electricity going off(b) his health, and in particular not getting the necessary medication for his thyroid condition(c) having to wait 3 months for a biopsy(d) the young inexperienced staff and(e) the violent behaviour of other prisoners on his wing (including stabbings).(f) he said that he had not attended for drug tests because some of the staff had been bringing in drugs themselves and some had been “ done for corruption ”.[20]The professional witnesses (the Prison Offender Manager [‘POM’] and the Offender Manager [‘COM]’) did not support release on licence. The Applicant was a Category B prisoner but was expected to be recategorized to Category C and the professional witnesses were of the view that a period of stability in the less restrictive conditions of a Category C prison was needed before release on licence could be recommended.[21]The further information provided after the hearing included a number of positive entries made by staff between 20 May and 26 June 2024 and one negative one which was of little or no relevance to the Applicant’s risk of serious harm to the public. An updated risk management plan was also provided.[22]The panel did not agree with the professional witnesses. They concluded that the Applicant’s risk would be manageable on licence in the community with the proposed management plan in place. The setting aside of the 2004 decision[23]Following the 2004 hearing the POM notified PPCS of further instances of poor behaviour which were said to be escalating, and as a result PPCS made an application to the Board for the panel’s decision to be set aside.[24]On 31 October 2024 that application was considered by a judicial member of the Board who decided that the panel’s decision should be set aside and a fresh hearing should take place and be conducted by another panel.[25]A brief summary of recorded instances of poor behaviour which resulted in the setting aside of the 2004 panel’s decision is as follows:(a) 16 July: approaching staff and informing them that his toilet would not flush, he had not had a shower for days, refusing to ‘bang up’ and threatening to get on the netting and slash the throat of any member of staff that approached him. [The Applicant says that he never made that threat and he would certainly have been charged with a disciplinary offence if he had.](b) 27 July: screaming abuse at a staff member on the landing ‘regarding the regime and cleaners not having the time to clean'. [He says she had previously called him disgusting.](c) 8 August 2024: abuse of a staff member who, due to a staff shortage, was bringing food to prisoners’ doors.(d) 13 August: accessing the safety netting due to issues surrounding his parole and the Offender Management Unit [He remained on the netting for 24 minutes and as a result of this incident he was dismissed from his job as a cleaner.](e) 13 August: using an obscene expression to a female member of staff who brought him the news that he was to be released.(f) 25 August: flooding his cell [This resulted in an adjudication. He says he didn’t do it deliberately, he had kicked a bag with bottled water in it in frustration.](g) 2 September: abuse of a member of staff during a lockdown search.(h) 2 September: smashing his observation panel, throwing food, eggs and water at prison staff and NHS staff, and being verbally abusive to them. [This resulted in his being moved to the segregation unit and charged with a disciplinary offence. The adjudicating officer accepted it was not the Applicant throwing water at the staff member but the Applicant did throw eggs out of his observation panel. The Applicant states that this was due to having been locked down for a number of days and having had his eggs smashed during a cell search, so he wanted them out of his cell.](i) 17 September: sending an abusive message to the Offender Management Unit. [He says it was sent to Reception and should not have gone to the OMU].(j) 17 September: refusing to take a mandatory drug test [he says because the conditions were so poor and he was being managed by corrupt staff.](k) 23 September: making inappropriate remarks to a female staff member trying to engage her in conversation about corruption on the part of some staff members.(l) 30 September: continuously hurling abuse at a member of staff about issues on the wing.(m) 30 September: making threats to three members of staff that when he was released he would expose them as a jail because he felt they were not doing enough to help a particular prisoner who had been self-harming.(n) 12 October: making an obscene remark about a female member of staff.[26]Subsequent to these incidents there were a number of other recorded instances of poor behaviour. These can be briefly summarised as follows:(i) 29 November 2024: With another prisoner set off the fire alarm. [The Applicant apologised afterwards].(ii) 7 January 2025: Attempted to incite other prisoners to refuse to bang up, and constant threats to staff.(iii) 7 January 2025: Picked some sandwich packs off a trolley and walked off with them; when asked multiple times to put them back, he dropped all the food on the floor and walked off. [The Applicant says he dropped the food by mistake: he was told by a staff member to pick it up and would have done if the staff member had not been rude and demanding in front of other prisoners. He was concerned about his presentation to his peers.](iv) 7 January 2025: Tried to incite prisoners to disobey a direct order to vacate a cell, due to cell overcrowding. There were six prisoners in the cell and this is not allowed. The Applicant spoke up and told them to stay where they were. [He says that they had just been playing a game in the cell.](v) 20 January 2025: An Air Fryer was found in his cell. It was a communal Air Fryer and was not for in cell use. It was missing for days and should have been left in the kitchenette. [The Applicant did not deny that he had the air fryer, but he was dismissive towards this negative entry.](vi) 21 January 2025: Attempted to force his way onto the exercise yard in excess of 10 minutes late, after being informed that the yard had already been posted and roll called in. He then proceeded to run around the wing shouting threats to the staff. This was part of a mass indiscipline involving two other prisoners. [This entry was disputed by another member of staff in another entry which stated that the Applicant was actually trying to assist staff in de-escalating the situation.](vii) 22 January 2025: When served with paperwork relating to the incident on the previous day launched into a barrage of abuse which included homophobic slurs and threats.(viii) 7 February 2025: Attended medicine hatch for morning medications without his I.D. Card and became abusive when challenged. [He says that he has an underactive thyroid that he takes medication for, and a side effect is that he can experience mood swings. He was frustrated with Health staff as he had been on this medication for 2 years and they knew it was him.](ix) 19 March 2025: Search of his cell found smoking paraphernalia, unknown bank details and a TV that appeared to have been tampered with.(x) 2 April 2025: Set off his fire alarm as his door was not unlocked when he wanted it to be.(xi) 3 April 2025: During a cell clearance a number of illicit articles were found including suspicious tablets, bank details, an email address and an improvised weapon. [The Applicant denies having an improvised weapon. He states it was a mackerel lid that he had manipulated to block the door.](xii) 3 April 2025: A planned removal was done on the Applicant due to him threatening to stab staff should they enter his cell. He was non-compliant and relocated to the segregation unit. [The Applicant gives the following account: When he and other prisoners were in the yard the general alarm was called due to a prisoner on the netting. He had been annoyed but did come back inside. He and another prisoner talked the individual off the netting, for which he was thanked by staff. Officers then came to his door with shields and told him to comply with instructions, which he did. After they applied cuffs, they slammed him into the wall and assaulted him. A knee was applied to his neck, and he lost consciousness. No pictures were taken of his injuries despite his request, and he was not given medical treatment for them. He was given mixed messages as to why he was on the Segregation Unit. One explanation was that he refused to come in off the yard, which he did not, and that he caused disruption on the wing, which he did not. He was then told that it was for threatening to stab staff, which he did not. He accepted being verbally abusive towards staff afterwards. He believed that he had been targeted due to commenting on officers’ treatment of another prisoner, and that the reason for moving him to the Segregation Unit was changed in an effort to hide the fact that staff assaulted him.](xiii) 3 April 2025: Made threats to staff due to him being unhappy about being restrained earlier. He said he would 'terrorise them upon his release', and he would get his boys on the outside to do them and is not arsed about getting lifted off on a 40 rec to get his revenge. This was all recorded on camera.(xiv) 13 April 2025: A line was found from his window. [The Applicant states that the line was not his and had been left there by a previous occupant.](xv) 15 April 2025: Conducted a three-way call which is not permitted. [The Applicant states that he had been speaking to his daughter and talking to her about what he is going through right now and the loss of his friend. Then another call came from another family member and his daughter put him on loudspeaker so he could reassure them that he was okay. His numbers were removed as part of this. He was aggrieved by that. He accepted that he breached communication rules, but he felt that it was obvious that his daughter was struggling and he should be able to support her]. (xvi) 16 April 2025: A staff member attempted to hold a ‘Post Use of Force’ debrief with the Applicant but although he originally engaged in the debrief he soon made threats to specific staff he believed acted improperly throughout the course of his planned removal to the Segregation Unit. (xvii) 27 April 2025: Due to an active fire in progress officers were locking up prisoners when the Applicant shouted threats to one of the officers. [The Applicant stated that this was aimed at one of the officers who had assaulted him: he said that he had needed to say this to get it off his chest, man to man.][27]There were a number of positive entries during this period as well as the negative ones. The 2025 hearing[28]This hearing took place remotely by video link on 12 June 2025. The panel comprised a judicial chair, a psychologist member and an independent member of the Board. The Applicant was legally represented. The dossier contained 562 numbered pages. The panel took oral evidence from the Applicant, the POM, a prison psychologist and the COM. The prison psychologist and the COM supported release on licence but the POM did not.[29]At the conclusion of the hearing it was agreed that the Applicant’s legal representative would provide closing submissions in writing. They were duly provided on 12 June and the panel’s decision not to direct the Applicant’s release on licence was issued on 24 June.[30]It is convenient to note at this point, to keep things in chronological order, that when the Applicant’s categorisation was reviewed it was decided that he should remain a Category B prisoner. This would have been irrelevant to the panel’s decision so I need to say no more about it. The Relevant Law The test for release on licence[31]The Codified Public Protection Test specifies that a panel of the Board can only direct a prisoner’s release on licence if it is satisfied that the prisoner’s continued confinement in prison is no longer necessary for the protection of the public; the panel can only be so satisfied if it considers that, if the prisoner were to be released into the community, there would be no more than a minimal risk of his committing a further offence of a kind which might result in serious harm to somebody else. The rules relating to reconsideration of decisions[32]Rule 28(1) of the Parole Board Rules 2019 (as amended) provides so far as is relevant for present purposes:(1) A party may apply to the Board for the case to be reconsidered on the grounds that the decision (a) contains an error of law; (b) is irrational; or (c) is procedurally unfair.(2) Decisions are eligible for reconsideration only where the prisoner is serving (a) an indeterminate sentence; (b) an extended sentence; (c) a determinate sentence subject to initial release by the Board under Chapter 6 of Part 12 of the 2003 Act; (d) a serious terrorism sentence.(3) An application for a provisional decision to be reconsidered under paragraph (1) must be made and served on the other party no later than 21 days after the decision is sent to the parties. The definition of irrationality[33]The power of the courts to interfere with a decision of a competent public authority on the ground of irrationality was defined in Associated Provincial Houses Ltd -v- Wednesbury Corporation 1948 1 KB 223 by Lord Greene as follows:
“if a decision on a competent matter is so unreasonable that no reasonable authority could ever have come to it, then the courts can interfere”
. The Parole Board is a public authority for that purpose, and the Wednesbury test therefore applies to applications to the High Court for judicial review of a panel’s decision. It also applies to applications to Reconsideration Panels of the Board for reconsideration of a panel’s decision on the ground of irrationality.[34]In R (DSD and others) -v- the Parole Board 2018 EWHC 694 (Admin) (‘the Worboys case’) a Divisional Court applied this test to Parole Board decisions in these words:
“the issue is whether the release decision was so outrageous in its defiance of logic or accepted moral standards that no sensible person who had applied his mind to the question to be decided could have arrived at it.”
The same test of course applies to “no release” decisions.[35]In R (on the application of Wells) -v- Parole Board 2019 EWHC 2710 (Admin) Mr Justice Saini set out what he described as a more nuanced approach in modern public law. This approach is “to test the decision maker’s ultimate conclusion against the evidence before it and to ask whether the conclusion can (with due deference and with regard to the panel’s expertise) be safely justified on the basis of that evidence, particularly in a context where anxious scrutiny needs to be applied”. This formulation of the test was adopted by a Divisional Court in the case of R (on the application of the Secretary of State for Justice) -v- the Parole Board 2022 EWHC 1282 (Admin) .[36]As was made clear by Mr Justice Saini, this is not a different test from the Wednesbury test. The interpretation of (and application of) the Wednesbury test in parole hearings (as explained in the Wednesbury and DSD cases) was of course binding on Mr Justice Saini. It is similarly binding on Reconsideration Panels.[37]It follows from these principles that in considering an application for reconsideration a Reconsideration Panel cannot substitute its own view of the evidence for that of the panel who heard the witnesses and were able to assess their reliability. The Reconsideration Panel will only direct reconsideration on the ground of irrationality if the Wednesbury test is satisfied. Procedural unfairness[38]Procedural unfairness means that there was some procedural impropriety or unfairness resulting in the proceedings being fundamentally flawed and therefore, producing a manifestly unfair, flawed, or unjust result. These issues (which focus on how the decision was made) are entirely separate from the issue of irrationality which focusses on the actual decision.[39]Examples of procedural unfairness which may be a ground for quashing a panel’s decision on this ground are where:(a) express procedures laid down by law were not followed in the making of the relevant decision; or(b) the party was not given a fair hearing;(c) the party was not properly informed of the case against them;(d) the party was prevented from putting their case properly;(e) the panel did not properly record the reasons for any findings or conclusion; and/or(f) the panel was not impartial.[40]These are not the only possible grounds for a finding of procedural unfairness but they are the ones most commonly alleged. The overriding objective is to ensure that the Applicant’s case was dealt with justly. The application for reconsideration of the panel’s decision[41]This application is admirably clear and concise. It reads as follows:
“The Applicant seeks reconsideration of the Parole Review on the basis that the decision in this case was irrational, procedurally unfair and went against the weight of the evidence.” “The Prison Offender Manager gave evidence with regard to documented behaviours and sought to rely upon the same to demonstrate that the Applicant needed to demonstrate a period of stability before he was safe to release. However, in her evidence she accepted that some of the documented entries supporting her view had been made erroneously or were inaccurate. This was, to some extent supported by evidence in the Applicant’s possession that was presented to the Panel. She also accepted that the prison had been subjected to valid and serious criticisms during this review period as documented by the Prisons Inspector. In our submission this called into question her assessment of the manageability of risk. The prison psychologist assessed that risk had been reduced, that risk of violence in the community was moderate with low imminence and she considered that the release risk management plan was sufficiently robust to manage risk. She also considered that there would be warning signs that would be identified that would indicate any potential increase in risk of serious harm likely to impact on behaviour that could cross the serious harm threshold. The Community Offender Manager agreed with the prison psychologist. Whilst she assessed that the Applicant posed a high risk of serious harm should he re-offend, she assessed that risk was not imminent, that there would be clear warning signs of any potential increase in risk and so risk could be managed. All witnesses agreed that the Applicant’s history of negative behaviours during the review period directly related to his environment and the regime rather than being linked to risk of serious harm and those behaviours were not offence paralleling. Indeed, he did not display any behaviours that would cross the serious harm threshold despite being subjected to the use of excessive force and despite displaying negative behaviours born out of frustration with the regime. The Applicant will say that the panel relied solely upon the evidence of the POM in reaching their decision together with the documented entries about his negative behaviours and failed to attribute any weight to the evidence undermining some of those entries and without attributing any weight to the evidence presented by other professionals as well as his own evidence. He believes that the Panel also failed to attribute any weight to the fact that he has not behaved in a violent way for many years. In addition, he submits that the evidence in respect of his negative behaviours did not show any behaviours that crossed the serious harm threshold. This view was reiterated by both the prison psychologist and the COM. Therefore, he will assert that the amount [sic] weight placed upon the evidence from the negative entries and security information was wholly inappropriate and unfair…”
The reply on behalf of the Respondent[42]As noted above the Respondent has offered no representations in respect of this application. Discussion[43]I have carefully examined the panel’s decision to see whether the legal representative has made out her case for findings of irrationality and/or procedural unfairness.[44]Among other things the panel recorded in some detail the various reported instances of poor behaviour to which I have referred above. They went on to record as follows the evidence of the professional witnesses and that of the Applicant.[45]The POM’s evidence as recorded by the panel included the following:
“In her report, the POM acknowledged that whilst the Applicant may have felt frustrated over the previous few months following the set aside a [sic] decision it did not excuse his behaviour. However, he claimed that he would work with Probation in the community if released and abide by his licence conditions. The POM acknowledged that the Applicant was unlikely to progress at the same prison and she said that the working relationships between him and staff are ‘damaged beyond repair’. Nevertheless, she felt he needed to evidence a period of stability and positive behaviour in custody prior to being released.” “In her evidence, the POM spoke of the well-known problems at the prison, noted in various inspections that could have added to the Applicant’s frustrations. These related particularly to staffing issues which often resulted in prisoners being locked in their cells for lengthy periods. There were also issues relating to drugs, mobile phones, weapons and drones flying in illicit materials. The POM spoke of the difficult relationship that the Applicant has had with her predecessor. She said that she had endeavoured to work with the Applicant. There had [sic] several conversations during which at times the Applicant was talking over her. He also appeared to have a good relationship with some members of staff. She conceded that some [sic] the younger members of staff may have had poor communication skills. She accepted that the Applicant had not displayed actual violence. She expressed concerns as to how the Applicant would behave in the community if he felt disrespected or ruminated about situations; she expressed concern as to whether or not he would be able to walk away and handle situations in a prosocial way. She remained concerned about his poor emotional responses for example when he had been abusive to healthcare staff. She was aware that on occasions the Applicant would smoke cannabis although there were no reports of him being continually under the influence. She was also uncertain as to how far the Applicant’s family would be a protective factor since they had not appeared to have prevented previous offending. She noted the Risk Management Plan which included a period in a PIPE AP and engagement with MBT but she was not supportive of release at the present time.”
[46]The prison psychologist’s evidence as recorded by the panel included the following:
“In the prison psychologist’s report dated 8 May 2025, she considered that the Applicant did not present as an imminent risk of physical violence although she conceded that non-compliance specifically in terms of his relationships with professionals was of concern. She concluded that the Applicant’s risk could be managed in the community following a successful period of engagement with IIRMS prior to release to support him and developing his insight, coping and communication skills as well as the professionals’ ability to work with him in a psychologically informed way. She said that this was considered ‘integral to his future risk management’ before he was released in the community.” “The prison psychologist supporting release assessed that non-compliance was the main area of concern in the event of the Applicant’s release. She described his recent behaviour as a mixture of feelings of being treated unfairly yet not dealing with it appropriately and still treating the prison as an antisocial lifestyle. She also believed that he experienced a lack of hope following the set aside a decision. She said that the Applicant clearly had problems dealing with operational staff whilst at the same time wishing to display an element of ‘bravado’ in front of other prisoners. However, she noted that there had been no evidence of actual violence and she did not believe that there was an imminent risk of serious harm if released. She believed that he still needed to develop skills but that this could be achieved through a period in a PIPE AP and with MBT. She believed his main risk was from verbal aggression and that staff should be able to cope. She saw no need for a move to a Category C establishment…” “She confirmed possible warning signs that she had set out in her report which included: anti-social peers; lack of stability including problems with finance and accommodation; possible increased drug use; family issues including pressure to provide for his family; feelings of injustice; poor emotional management; lack of transparency/conflict with professionals; non-compliance; and lack of purposeful activity including employment.”
[47]The COM’s evidence as recorded by the panel included the following:
“In her 4 June 2025 report, the COM agreed that the Applicant would benefit from engagement with the IIRMS-Resettle project designed for individuals with complex interpersonal difficulties; participation in the programme required a minimum two-year commitment whilst on licence. The COM discussed the situation with the IIRMS manager who reported that the assessment process takes approximately six months and includes initial paper screening followed by a minimum of three in-custody interviews. The current waiting list is approximately 18 months with an anticipated programme start date around May 2027; however, in-reach support could begin upon acceptance to prepare the Applicant for transition into the full programme. The COM suggested that alternative interventions could be accessed more promptly in the community via a PIPE AP and Mentalisation Based Therapy (MBT) groups via the OPD pathway. She noted that the Applicant had not yet consented to IIRMS in the light of the extended waiting period.”
[48]The Applicant’s evidence as recorded by the panel included the following:
“As regards his recent behaviour, whilst he sought to deny or downplay several of the incidents, he did seem to accept that he had reacted verbally in an inappropriate way of several occasions. He claimed that his response was very much linked to the conditions in prison and the approach of staff and he did not believe that it would be replicated in the community. He spoke about the appalling conditions in the prison with toilets not working and lack of fresh drinking water. He was very concerned as he had a potential cancer diagnosis as well as thyroid problems. He agreed that at times he responded poorly to staff using expressions such as ‘knob-head’ and that did he not want to be seen as a ‘pushover’ in front of other prisoners. He was particularly aggrieved at the incident on 3 April 2025 when he was forcibly removed to the segregation unit for reasons which he claimed were entirely unjustified. He said that he received serious injuries which were recorded on paper but no photographs were ever taken. He read to the panel some extracts from prison documents in which it appears that some of his complaints made to the Prison Governor were accepted. He admitted using cannabis on occasions although he said it was clear that he was not addicted; however, he did admit that had there been drug tests (which he had refused), he would have tested positive. Overall, he said that he now had a much better concept of life wanting to spend time with his mother, sister, daughter and family and determined to live a pro-social lifestyle. He said that he would be willing to go to a PIPE AP for the time required and thereafter hoped to live with his mother although recognised safeguarding issues involving his niece. He said he had previously worked as a chef which he could recommence and also had trained as a carpenter.”
The panel’s conclusions[49]The concluding section of the panel’s decision reads as follows:
“The panel has considered all the written and oral evidence as well as the closing submissions from the legal representative. The panel needs to consider the risks of the public if the Applicant was to be now released not only until the end of his sentence but for the foreseeable period thereafter. The index offence involved a high level of cruelty both to the victim and to her parents. The Applicant and his associates were involved in a drugs world where problems were solved by the use or threats of violence without any concern as to the harm to victims. The Applicant expressed to the panel a level of victim awareness although the panel remained unconvinced. Whilst the panel accepts that the Applicant was extremely upset with the set aside decision and also had continuing problems coping with some staff at the prison, his behaviour which led to the set aside decision which has continued notwithstanding the parole window clearly indicates to the panel that the Applicant’s coping skills and emotional response certainly in custody require further work and at least an ability to display a period of sustained good behaviour. The panel do not accept that this high volume of negative entries and poor response to staff is likely to suddenly end if released; to that extent it disagrees with the evidence from the prison psychologist and the COM. It appears to the panel that the Applicant has still a poor attitude to authority, continues to display anti-social behaviour, poor problem-solving skills and will push boundaries. The panel do not believe that he will be compliant if released and there remains the risk of conflict and possible physical harm once he is in the community. The panel is satisfied that further core offending work needs to be completed in custody and the Applicant needs to display a sustained period of compliant and pro-social behaviour before the panel can be satisfied that he can be safely managed in the community. Accordingly, the panel concludes that it is necessary for the protection of the public that he remains detained and release is not directed.”

Decision

[50]I have considered very carefully the panel’s reasons for their decision and the legal representative’s criticisms of that decision.[51]This is not an easy case to decide and it is one in in which views could and did reasonably differ. I have however reminded myself of the Wednesbury test for irrationality and I am afraid I cannot conclude that the panel’s decision in this case was one to which no reasonable panel could have come. Equally I cannot find that there was any procedural unfairness in the panel’s handling of the case. I have a good deal of sympathy for the Applicant but I cannot allow that to prevent me from making what I am bound to find is the correct decision which is to refuse this application.[52]The panel’s key findings were:(a) that the high volume of negative entries and poor response to staff was unlikely to end suddenly if the Applicant was released on licence and(b) that he was unlikely to comply with supervision in the community.[53]I cannot find that those findings were ones which no reasonable panel could have reached. The panel had the advantage of seeing and hearing the Applicant giving evidence, and I am satisfied that they had defensible reasons for their findings.[54]I agree with the legal representative that many of the reported instances of poor behaviour were of little if any relevance to the Applicant’s risk of serious harm to the public in the community, but it is concerning that others are indicative of beliefs and attitudes which the Applicant was unable to control at a time when he knew he was coming up for his parole hearing. I am satisfied that in the absence of evidence of a proven ability to control those beliefs and attitudes in prison it was not unreasonable for the panel to conclude that they were liable to recur at Approved Premises or elsewhere in the community.[55]Equally I am satisfied that, to put it no higher, there was a real likelihood that the Applicant would fail to comply with the requirements of those managing him in the community.[56]Whilst the prison psychologist was supporting the Applicant’s release on licence, that was on the basis that he would first need to complete a successful period of engagement with IIRMS: in her view that was ‘ integral to his future risk management ’. The Applicant has been understandably reluctant to sign up to the IIRMS route in view of the lengthy timescale. If the IIRMS proposal was to be implemented there would need to be an adjournment to see whether it had been successful, and such an adjournment would be well beyond the length considered appropriate by the Board. The COM’s suggested alternatives seem still to have been in the process of development and it does not seem to have been clear whether they would have been sufficient to meet the Applicant’s needs.[57]I cannot agree that the panel relied solely on the POM’s evidence or that they failed to attribute any weight to the Applicant’s evidence or that of the other professionals. They clearly had in mind the fact that the Applicant had not behaved in a violent way for many years, and they certainly took that fact into account. Equally they certainly gave close consideration to the evidence of the Applicant and the other professionals.[58]The panel were of course aware that there were no accredited risk-reduction programmes available to the Applicant. As is often the case that did not mean that there was no further work for him to do to reduce his risk to the public. All three professionals agreed that to be the case.[59]It follows from the above that I am afraid I must refuse this application for reconsideration. Jeremy Roberts 12 August 2025