Crook, Application for Reconsideration by, [2025] PBRA 278 (18 December 2025) [2025] PBRA 278

PBRA
Crook, Application for Reconsideration by, [2025] PBRA 278 (18 December 2025)
[2025] PBRA 278 · 2025-11-07
[1]This is an application by Crook (the Applicant) for reconsideration of a decision of an oral hearing panel dated 7 November 2025 not to direct release.[2]Rule 28(1) of the Parole Board Rules 2019 (as amended) provides that applications for reconsideration may be made in eligible cases (as set out in rule 28(2)) on the basis(a) that the decision contains an error of law,(b) that it is irrational and/or(c) that it is procedurally unfair. This is an eligible case, and the application was made in time.[3]I have considered the application on the papers. These are: · The Oral Hearing Decision · The Submissions advanced on the Applicant's behalf, which are dated 26 November 2025 · The dossier, which currently consists of 470 numbered pages, the last document being the Decision Request for Reconsideration[4]The grounds for seeking a reconsideration are as follows:
"The application for reconsideration is made on the grounds of irrationality. The panel have attached weight to historic allegations without making a finding of fact in respect of them."
Background[5]The Applicant was 41 years old in 2021 when he received an extended sentence for public protection for sexual offences against a 14-year-old girl, which resulted in her becoming pregnant. The sentence comprised 6 years' custody and an 8-year extended licence period. His parole eligibility date was 14 December 2024, his conditional release date is 14 December 2026, and the sentence expiry date is December 2034. He is now 45 years old.[6]The Applicant had previous convictions which had no relevance to sexual offending. During the course of the present review, it came to light that in 2010, 10 years before the index offences, someone had made allegations that the Applicant had subjected child members of his family to sexual abuse between 1987 and 1992. There was no investigation in 2010. It is the way in which the panel dealt with these allegations that gives rise to the sole basis on which the application for reconsideration is put.[7]The allegations came to the Community Offender Manager's (COM's) attention when she made a safeguarding referral when preparing her risk management plan. Current parole review[8]The Secretary of State's (the Respondent's) referral is dated 5 March 2024. It asks the Parole Board to consider making a direction for release. The panel met on 19 June 2025, when the historic allegations were brought to its attention. The panel adjourned the case for further information about the allegations, and to enable the Applicant to consider them and give instructions about them to his representative. The Applicant received a redacted version of the relevant police report.[9]The hearing resumed on 23 October 2025 and took place via video link. The panel, which consisted of three independent members of the Parole Board, heard evidence from the COM, the previous and current Prison Offender Managers (POMs), a forensic psychologist, and the Applicant. The Applicant was represented throughout. His representative was able to ask questions of all the witnesses, including the Applicant, and to make written submissions to the panel. The Relevant Law[10]The panel correctly sets out in its decision the test for release. Parole Board Rules 2019 (as amended)[11]The Parole Board Rules provide the types of sentence and decision which are eligible for reconsideration. This was an eligible sentence type and an eligible decision for reconsideration. Irrationality[12]The power of the courts to interfere with a decision of a competent tribunal on the ground of irrationality was defined in Associated Provincial Houses ltd -v- Wednesbury Corporation [1948] 1 KB 223 by Lord Greene in these words " 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 same test applies to a reconsideration panel when determining an application on the basis of irrationality.[13]In R (DSD and others) -v- the Parole Board [2018] EWHC 694 (Admin) a Divisional Court applied this test to Parole Board hearings in these words at para 116:
"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. "
[14]In R (on the application of Wells) -v- Parole Board [2019] EWHC 2710 (Admin) Saini J set out what he described as a more nuanced approach in modern public law which was "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 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).[15]As was made clear by Saini J this is not a different test to the Wednesbury test. The interpretation of and application of the Wednesbury test in Parole hearings as explained in DSD was binding on Saini J.[16]It follows from those principles that in considering an application for reconsideration the reconsideration panel will not substitute its view of the evidence for that of the panel who heard the witnesses.[17]Further while the views of the professional witnesses must be properly considered by a panel deciding on release, the panel is not bound to accept their assessment. The panel must however make clear in its reasons why it is disagreeing with the assessment of the witnesses. The reply on behalf of the Secretary of State[18]The Respondent has chosen not to make any reply to this Application. Discussion[19]The single issue raised is that the panel took into consideration the unproven allegations in reaching its conclusion.[20]This being the ground argued, it is perhaps surprising that the application makes no reference to the leading case on this topic, the decision of the Supreme Court in R (Pearce) v Parole Board and another [2023] UKSC 13 . The Supreme Court summarised its conclusions at Paragraph 87:
"(i) There is no general legal rule that in making a risk assessment the Board must adopt a two-stage process of making findings of fact on the balance of probabilities and then treating only those matters on which it has made findings of fact as relevant to the assessment of risk. "(ii) The Board's task is to address whether the safety of members of the public requires that the prisoner should remain confined. In so doing, the Board must have regard to the consequences of its decision on the interests of the prisoner, and the hardship he may suffer if he no longer needs to be confined in order to protect the public. "(iii) There is no rule of substantive fairness, akin to a legitimate expectation, which requires the Board to have regard only to found facts in its assessment of risk. "(iv) What procedural fairness requires of the Board in its impartial performance of its statutory remit is determined by the statutory terms of that remit and the wider legal context of the common law. "(v) If weight is to be given to an allegation of criminal or other misbehaviour in the risk assessment, the Board should first attempt to investigate the facts to enable it to make findings on the truthfulness of the allegation. If, as may often be the case despite its efforts to obtain the needed information, the Board is not able to make such a finding, it should investigate the facts to make findings as to the surrounding circumstances of the allegation which may or may not point to behaviour by the prisoner which is relevant to the assessment of risk. "(vi) In some circumstances, however, the Board may not be able to make findings of fact as to the truth of an allegation either because of an inability to obtain sufficiently reliable evidence or because it would be unfair to expect the prisoner to give an answer to the allegation when he is facing criminal or prison disciplinary proceedings in relation to that allegation. "(vii) In such circumstances the Board, having regard to public safety, may take into account the allegation or allegations and give it or them such weight as it considers appropriate in a holistic assessment of all the information before it, where it is concerned that there is a serious possibility that those allegations may be true. But the Board must proceed with considerable caution in this exercise because of the consequences of its decision on the prisoner. Procedural fairness requires the Board to give the prisoner the opportunity to make submissions about how the Board ought to proceed. There may be circumstances where, because of the inadequacy of the information available to the Board, it concludes that it should not take account of an allegation at all. There may also be circumstances where the information is less than would be desired but the allegation causes sufficient concern as to risk that the Board treats it as relevant. Its assessment of the weight to be attached to an allegation is subject to the constraints of public law rationality. "(viii) Thus, a failure to make findings of fact where it was reasonably practicable to do so or an irrational reliance on insubstantial allegations could be a ground of a successful public law challenge."
[22]The complaint made is that, as the panel could not make a finding in respect of the allegations, limited weight should be placed on them. A glance at Pearce would have satisfied the legal representative that, the panel having decided (perfectly reasonably) that it had insufficient material upon which to make a finding of fact, it was right to go on to consider what, if any, weight should be placed on the allegations in its holistic assessment of risk. In fact, as the application concedes, " there was minimal mention of the historical allegations " in the panel's decision.[23]The panel's conclusion that the Applicant did not meet the test for release was based on a number of matters, but the allegations did not feature as one of them, save that the panel noted that all the professionals involved in the case had considered the possibility that the Applicant's abusive behaviour had spanned a much longer period than previously thought and involved both male and female children. The panel considered the allegations when it listed potential risk factors.[24]The panel also considered a security entry from April 2025 referring to the Applicant having been found with a USB stick containing images of child sexual abuse. It was not able to find any satisfactory evidence about this. Its conclusion was that "[I]t was not possible for the panel to make any finding in relation to this, save to note that, like the historical allegations, (which suggested the possibility that [the Applicant's] offending had involved both male and female child victims, and had spanned a lengthy period), the possibility that [the Applicant] has an ongoing interest in images of child sexual abuse should be taken into account in future risk assessments ." Very properly, no complaint is made about the panel's approach to the evidence about the USB stick, which in fact featured in the panel's concluding summary of the reasons for its decision, as the historical allegations did not.[25]The professional witnesses all expressed the professional opinion that the Applicant's risk of serious harm could not be managed in the community, both before and after they were aware of the historical allegations.[26]The panel's approach to the historical allegations was entirely in accordance with the leading authority and was unimpeachable. The Application for Reconsideration, based on criticism of the panel for its approach, is misconceived. There was ample evidence that the Applicant did not pass the test for release. Decision[27]For the reasons I have given, I do not consider that the decision was irrational, and accordingly the application for reconsideration is refused. HH Patrick Thomas KC 18 December 2025