Chief Constable of Derbyshire Constabulary, R (On the Application Of) v Police Misconduct Panel [2026] EWHC 467 (Admin) (09 February 2026)

Chief Constable of Derbyshire Constabulary, R (On the Application Of) v Police Misconduct Panel [2026] EWHC 467 (Admin) (09 February 2026)

The Panel's findings regarding the content and impropriety of the telephone calls were adequately reasoned and within the range of decisions open to it. The Panel was not required to reference all evidence in detail and properly assessed witness credibility. However, the Panel's written reasons for imposing final written warnings rather than dismissal lacked adequate explanation and were inconsistent with its findings regarding the failure to follow superior advice and the seriousness of the misconduct. This amounted to a public law error in reasoning on sanction.

Citation
[2026] EWHC 467 (Admin)
Parties
Claimant: Chief Constable of Derbyshire Constabulary; Defendant: Police Misconduct Panel; Interested Party: PC Jack Large; Interested Party: PC James Barker
Jurisdiction
England and Wales
Judgment Date
09 February 2026
Procedural Posture
Judicial Review / Final Judgment
Outcome
Claim allowed in part; Panel's decision on sanction quashed and remitted for reconsideration.
Legal Topics
Police Misconduct, Gross Misconduct, Disciplinary Proceedings, Adequacy of Reasons, Sanctions, Judicial Review Standards
Administrative Law Police Law Employment Law Police Misconduct Gross Misconduct Disciplinary Proceedings Adequacy of Reasons Sanctions +1 more

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Parties

Chief Constable of Derbyshire Constabulary

Claimant

Police Misconduct Panel

Defendant

PC Jack Large

Interested Party

PC James Barker

Interested Party

Procedural Posture

Judicial Review / Final Judgment

Legal Issues

  1. 1 Did the Police Misconduct Panel err in law or act irrationally in its findings regarding the conduct of PC Large and PC Barker?
  2. 2 Did the Panel provide legally adequate reasons for its findings?
  3. 3 Was the Panel's decision on sanction inconsistent with its factual findings and outside the range of reasonable responses?

Ratio Decidendi

The Panel's findings regarding the content and impropriety of the telephone calls were adequately reasoned and within the range of decisions open to it. The Panel was not required to reference all evidence in detail and properly assessed witness credibility. However, the Panel's written reasons for imposing final written warnings rather than dismissal lacked adequate explanation and were inconsistent with its findings regarding the failure to follow superior advice and the seriousness of the misconduct. This amounted to a public law error in reasoning on sanction.

Court Disposition

Claim allowed in part; Panel's decision on sanction quashed and remitted for reconsideration.

Orders

  • Panel's decision imposing final written warnings on PC Large and PC Barker quashed.
  • Matter remitted to Police Misconduct Panel for reconsideration of sanction.