Dixon, R (on the application of) v The Secretary of State for Justice [2017] EWCA Civ 961 (14 July 2017)

Dixon, R (on the application of) v The Secretary of State for Justice [2017] EWCA Civ 961 (14 July 2017)

The delay in providing the psychological assessment was not sufficiently serious, given staffing/resource realities, to constitute a breach of the ancillary duty under Article 5.4 ECHR; no damages are payable.

Citation
[2017] EWCA Civ 961
Parties
Claimant/appellant: Francis Dixon; Defendant/respondent: Secretary of State for Justice
Jurisdiction
England and Wales
Judgment Date
14 July 2017
Procedural Posture
Judicial Review Appeal / Court of Appeal, Post High Court Judgment
Outcome
Appeal dismissed; permission to appeal on second ground refused.
Legal Topics
Article 5 ECHR, Parole Board Review, Delay in Prisoner Release, Ancillary Duty Under Article 5.4, Damages for Breach of ECHR

Case Brief

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Parties

Francis Dixon

Claimant/appellant

Secretary of State for Justice

Defendant/respondent

Procedural Posture

Judicial Review Appeal / Court of Appeal, Post High Court Judgment

  1. 1 Whether delay in providing psychological assessment breached Article 5(4) ECHR or ancillary duty
  2. 2 Whether delay justified by staffing/resource issues
  3. 3 Whether damages are payable for breach

Ratio Decidendi

The delay in providing the psychological assessment was not sufficiently serious, given staffing/resource realities, to constitute a breach of the ancillary duty under Article 5.4 ECHR; no damages are payable.

Court Disposition

Appeal dismissed; permission to appeal on second ground refused.

Orders

  • No damages awarded.
  • No declaration of breach.