“We submit that the decision not to direct release is procedurally unfair for the following reasons: - “1. The contention that core risk reduction work remains outstanding was not evidenced and is based on erroneous information. “2. Insufficient reasons were provided to substantiate the view that risk cannot be properly safeguarded and managed in the community. “In paragraph 3.7 of the decision, the Panel noted; “The [prison offender manager (POM)] had been responsible for [the Applicant’s] case soon after recall and did not support release. He noted that [the Applicant] had been assessed as suitable for moderate intensity Building Choices.” “During evidence, the POM confirmed that he had used a statutory online tool which confirmed that in principle [the Applicant] had been deemed suitable for moderate Building Choices. When asked to confirm whether an actual programme need assessment had been carried out, he confirmed it had not and therefore could not be confident whether or not [the Applicant] would be assessed as eligible for this programme not withstanding his suitability by way of the dynamic factors used to make the online assessment. “In paragraph 3.6, the [community offender manager (COM)] further indicated: - “she was unsure whether accredited work could be completed in the community because she could not guarantee that [the Applicant] would be assessed as suitable”. “Neither professional witness highlighted in depth what if any core risk reduction work was outstanding and the COM stated that it would be “her preference for any further work to be completed in closed conditions”. “The Panel in their findings indicated at paragraph 4.4: - “in the absence of work to address risk factors, the Panel considered [the Applicant] to present a greater than minimal risk the public. In the Panel’s assessment, work to address risk factors cannot be completed safely in the community and [the Applicant] does not meet the test for release”. “The Panel indicated in paragraph 4.3 that in their assessment they had concerns about relationships, thinking, behaviour, emotional management, lifestyle and compliance. The Panel formed a view that these are active risk factors that need to be addressed. “It is not established or evidence that [the Applicant] is eligible for any interventions within the custodial environment. A programme need assessment has not been completed and at best, it is said that he potentially maybe eligible for the moderate strand of Building Choices which we would suggest is not core reduction work that needs to be completed within a closed environment. “We submit that the Panel did not provide adequate reasons to justify their assessment that any treatment needs to be addressed in the closed estate, and why they cannot be addressed in the community. “Although mentioned fleetingly within the conclusion, the Panel do not appear to place enough weight on the fact that [the Applicant] was on licence for nearly 5 years following completion of intensive risk reduction work. “A Psychological Risk Assessment was completed in 2017 and determined all risk factors had been addressed and that there was no further risk reduction work identified for him to complete. “[The Applicant] vehemently denied the circumstances leading up to his recall, but the Panel was satisfied and the balance of probabilities that there was sufficient evidence to establish that [the Applicant] had breached the exclusion zone and had attended at his wife’s address. “This highlights a non-compliance issue with regards to licence conditions, but no further offences were committed, and no finding fact was made as regards to allegations highlighted within the Security Intelligence Report. On that basis, we submit that the Panel have not recorded sufficient reasons as to why [the Applicant’s] risk cannot be adequately safeguarded. “[The Applicant] indicated during his evidence that he has no intention of reestablishing relationships with his ex-wife and confirmed that he would be relocating to [a different area]. This was supported by his COM. Any risk therefore associated to his ex-wife could be adequately mitigated by the imposition of the GPS Tag and an Exclusion Zone to include a wider geographical area. “The Parole Board has a Statutory Duty to provide reasons for its decision.The Parole Board Rules 2019 , as amended in 2024, section 25 (6) (b). “Whilst it is accepted that there is not, in principle, a general duty to give reasons, the impact of the decision on an individual is relevant to the consideration of what reasons are required in interest of fairness. (Doody v Secretary of State for the Home Department and other appeals[1993] 3 ALL ER 92 ) “It is now increasingly implied that natural justice in fairness require adequate reasons, with this being increasingly the case when a judicial board, such as the Parole Board, is concerned. The leading case of South Buckinghamshire District Counsel v Porte (no 2)[2004] 1 WLR 1953 outlines reasons must be intelligible and adequate. While they may be concise, the individual concerned must be able to understand the reasons for the decision and what is required will depend on the circumstances of the case and what is at stake. “It is difficult to imagine a scenario of which more is at stake than an individual’s liberty of continued detention in a closed prison environment especially when the circumstances leading to recall are being vehemently denied. “It is submitted that the expectation would be for relatively extensive reasons to be provided for his continued detention and why the Panel feel that there remain active risk factors that require treatment, especially in the absence of any confirmation that he’s eligible for any such intervention. “Little focus and weight has been placed in our respectful submission as to the sustained and prolonged period of time that [the Applicant] spent in the community of licence set against the alleged breach of an Exclusion Zone.”
“ there must have been a mistake as to an existing fact, including a mistake as to the availability of evidence on a particular matter; the fact or evidence must have been "established", in the sense that it was uncontentious and objectively verifiable; the appellant (or his advisors) must not have been responsible for the mistake; and the mistake must have played a material (though not necessarily decisive) part in the tribunal's reasoning .”