Haddock, R (on the application of) v The Parole Board of England & Wales & Anor

Haddock, R (on the application of) v The Parole Board of England & Wales & Anor

The Parole Board's refusal to direct release and the Secretary of State's refusal to shorten the review period were not irrational or unlawful; both decisions were within the range of reasonable responses given the claimant's risk profile, prison conduct, and the need for public protection.

Parties
Claimant: Adam Haddock; First Defendant: The Parole Board of England & Wales; Second Defendant: Secretary of State for Justice (via Public Protection Casework Section)
Jurisdiction
England and Wales
Judgment Date
17 December 2014
Procedural Posture
Judicial Review / Judgment on the Merits After Oral Hearing
Outcome
Application for judicial review refused
Legal Topics
Parole, Judicial Review, Imprisonment for Public Protection, Risk Assessment, Wednesbury Unreasonableness
Criminal Law Administrative Law Prison Law Parole Judicial Review Imprisonment for Public Protection Risk Assessment Wednesbury Unreasonableness

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Parties

Adam Haddock

Claimant

The Parole Board of England & Wales

First Defendant

Secretary of State for Justice (via Public Protection Casework Section)

Second Defendant

Procedural Posture

Judicial Review / Judgment on the Merits After Oral Hearing

Legal Issues

  1. 1 Whether the Parole Board's refusal to direct the claimant's release was irrational or unlawful
  2. 2 Whether the Secretary of State's refusal to reduce the parole review period from 12 to 8 months was irrational or unlawful

Ratio Decidendi

The Parole Board's refusal to direct release and the Secretary of State's refusal to shorten the review period were not irrational or unlawful; both decisions were within the range of reasonable responses given the claimant's risk profile, prison conduct, and the need for public protection.

Court Disposition

Application for judicial review refused

Orders

  • Application for judicial review dismissed
  • Claimant entitled to detailed assessment of costs