Squire v Thames Valley Police & Anor (R. on the Application of)

Squire v Thames Valley Police & Anor (R. on the Application of)

The PAT had no evidential basis to find apparent bias or procedural unfairness in the panel's decision. The panel's explicit disavowal of reliance on inadmissible hearsay evidence must be accepted. The panel's findings on the core allegations were well-reasoned and justified. The PAT's decision to overturn the panel's findings was unsustainable. The sanction issue was properly remitted to the PAT for determination.

Parties
Appellant: Michael Squire; 1st Respondent: Chief Constable of Thames Valley Police; 2nd Respondent: Police Appeals Tribunal
Jurisdiction
England and Wales
Judgment Date
21 December 2016
Procedural Posture
Appeal (civil) / Appeal From Administrative Court Decision on Judicial Review
Outcome
Appeal dismissed; cross-appeal dismissed; High Court decision upheld
Legal Topics
Judicial Review, Police Misconduct, Procedural Fairness, Hearsay Evidence, Bias, Disciplinary Proceedings
Administrative Law Employment Law Police Law Judicial Review Police Misconduct Procedural Fairness Hearsay Evidence Bias +1 more

Case Brief

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Parties

Michael Squire

Appellant

Chief Constable of Thames Valley Police

1st Respondent

Police Appeals Tribunal

2nd Respondent

Procedural Posture

Appeal (civil) / Appeal From Administrative Court Decision on Judicial Review

Legal Issues

  1. 1 Whether the Police Appeals Tribunal (PAT) erred in finding apparent bias and procedural unfairness in the disciplinary panel's decision
  2. 2 Whether the PAT was entitled to overturn the panel's findings of gross misconduct
  3. 3 Whether the admission of hearsay evidence rendered the proceedings unfair

Ratio Decidendi

The PAT had no evidential basis to find apparent bias or procedural unfairness in the panel's decision. The panel's explicit disavowal of reliance on inadmissible hearsay evidence must be accepted. The panel's findings on the core allegations were well-reasoned and justified. The PAT's decision to overturn the panel's findings was unsustainable. The sanction issue was properly remitted to the PAT for determination.

Court Disposition

Appeal dismissed; cross-appeal dismissed; High Court decision upheld

Orders

  • All grounds of appeal by Michael Squire dismissed
  • Cross-appeal by Chief Constable of Thames Valley Police dismissed