Monthly News Archives: February 2023


Surrogacy, IVF and equality: JR176(2)’s application for judicial review

28 February 2023 by

Introduction

Two men are in a relationship and want to have a child. They approach a female friend who is happy to be their surrogate. She has previously had a voluntary sterilisation procedure, so she would need in-vitro fertilisation (IVF) using a donor egg (a procedure known as gestational surrogacy), to help her friends realise their wishes. This is where they all encounter a problem: voluntary sterilisation makes the woman ineligible for publicly funded IVF.

In JR176(2)’s application for judicial review [2022] NIKB 21, the two men challenged the eligibility criteria for publicly funded IVF on a number of grounds, among which this post will focus on two: a breach of the right to private and family life under Article 8 ECHR and Article 8 taken with the right not to be discriminated against contrary to Article 14 ECHR.


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The Weekly Round-up: Shamima Begum, UN resolution against Russia, and new law on Child marriages

27 February 2023 by

In the news

The UN General Assembly backed a resolution condemning Russia’s actions and calling for an end to the war on Thursday, the eve of the anniversary of the invasion. With 141 supporters, 32 abstentions and seven voting against, the resolution reiterated the UN’s support for Ukraine and called for a “comprehensive, just and lasting peace.” Abstentions included China, India and South Africa, while Russia, North Korea and Syria were among those voting against. General Assembly resolutions are not legally binding but carry great political weight, and the UN Security Council is obstructed from action by Russia’s veto. On the same day in Vienna, a large number of delegates walked out of a parliamentary assembly of the Organization for Security and Co-operation in Europe (OSCE) in protest against Austria’s decision to give visas to Russian officials.

Leading supermarkets in the UK have introduced customer limits on purchases of fruits and vegetables. According to the British Retail Consortium, the shortages are expected to last a few weeks until reliance on imports from Spain and north Africa is counteracted by the start of the UK growing season. Tom Bradshaw, one of the leaders of the National Farmers’ Union (NFU), has called for the UK to “take command” of its supply chains. Citing Brexit, the Ukraine War, and climate change, the NFU wants the government to use the powers granted it by the Agriculture Act 2020 to address exceptional market conditions.  


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Law Pod UK latest episode: Safe as Houses: Depriving children of their liberty

24 February 2023 by

Restricting the liberty of a child is a serious step only to be taken in the most difficult of circumstances. Children may require secure accommodation by the Local Authority in a variety of circumstances. A child could require urgent mental health treatment in a secure hospital. A child may require strict supervision with a high staff to child ratio, in order to protect them from harm and meet their complex needs. Applications are made where a child poses a significant risk of harm to themselves or others. Applications for secure accommodation or deprivation of liberty orders have increased significantly in recent years. There is now a severe lack of regulated accommodation, and the courts are having to use their inherent jurisdiction to approve DOLS regimes where unregulated placements are the only option. 

In Episode 179 of Law Pod UK Lucy McCann speaks to Richard Ager and Clare Ciborowska who examine the current situation and, in particular, consider the case of Re X (Secure Accommodation: Lack of Provision) [2023] EWHC 129 (Fam) in which Sir Andrew McFarlane, President of the Family Division of the High Court, gave a scathing Judgment on the provision of secure accommodation to children in England & Wales. The episode also explores the recent decision of Manchester City Council v P ([2023] EWHC 133 (Fam) which considered whether restrictions placed on a child in respect of mobile phone/internet use amounted to a deprivation of liberty.

The episode discusses the new national deprivation of liberty court. The Nuffield Family Justice Observatory recently published this report, analysing the first two months of applications to the national deprivation of liberty court.

Law Pod UK is available on Spotify, Apple PodcastsAudioboomPlayer FM,  ListenNotesPodbeaniHeartRadio PublicDeezer or wherever you listen to your podcasts. Please remember to rate and review us if you like what you hear.

Supreme Court finally weighs in on the Tate’s viewing platform

22 February 2023 by

In a headline-grabbing decision, the Supreme Court has decided that an observation platform at the Tate Modern Art Gallery (“the Tate”), which overlooks a number of nearby luxury apartments, gives rise to the tort of nuisance – read judgment

In 2017 a group of apartment owners from the Neo Bankside building issued proceedings complaining that visitors accessing the south side of the Tate’s observation platform could, and frequently did, look directly into the living areas of their homes (which have floor-to-ceiling windows). The judgments refer to visitors “peering in”, “looking”, in some instances waving to the flat occupants (friendly), and there was even a mention of someone looking in using binoculars (creepy). The evidence at trial also established that pictures taken from the platform, including views of the apartment interiors, had been posted on social media. The owners alleged that the Tate’s operation of the observation platform gave rise to the tort of nuisance, and they sought an injunction requiring it to prevent the intrusion they were experiencing (for example by blocking off that part of the platform), or damages in the alternative. 


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Raw sewage in the Court of Appeal

21 February 2023 by

The pumping of raw, untreated sewage into Britain’s waterways is one of the defining political issues of the day. Its potency as a legal issue, however, is limited. That, at least, is the outcome of R (Wild Justice) v OFWAT [2023] EWCA Civ 28.

Sewage polluting the River Coln, at Fairford, Gloucestershire, this January. Photograph: Graeme Robertson/Guardian

The Claimant, a not-for-profit organisation which advocates for the protection of wildlife and nature, asked the Court of Appeal for permission to apply for judicial review of the Respondent’s alleged failure to perform its duties to regulate the discharge of raw sewage. 

Permission had already been refused twice below – on the papers by Ellenbogen J, and at an oral hearing by Bourne J. This appeal was heard by Bean LJ.


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The Weekly Round-up: Earthquake aftermath, crimes against humanity, and Ukraine

20 February 2023 by

In the news 

The United States has formally determined that Russia has committed crimes against humanity in Ukraine. Speaking at the Munich Security Conference on Saturday, US Vice-President Kamala Harris accused Russia of ‘gruesome acts of murder, torture, rape and deportation’ and said those who had committed crimes would be held to account. UK Prime Minister Rishi Sunak also spoke at the event over the weekend, where he urged leaders to ‘double down’ on military support for Kyiv. 

Syria and Turkey continue to face devastating consequences in the aftermath of last week’s earthquakes. The death toll caused by the 7.8 magnitude tremor has surpassed 46,000 and is expected to continue to rise. In Turkey, the scale of the damage has been partly attributed poor construction practices and President Erdogan’s government has been criticised for failing to implement stricter building regulations. 

In Syria, the UN is facing backlash for failing to deliver humanitarian relief to the north-western, opposition-held regions of the country. The Syrian government has allowed two new border crossings to be opened from Turkey. The UN’s decision, however, to wait for President Assad’s permission to use these routes has been widely condemned. Meanwhile, the British government has pledged an additional funding package to support the earthquake recovery effort. 

Finally, Boris Johnson has urged Prime Minister Rishi Sunak not to abandon the Northern Ireland Protocol Bill. Set in motion by Mr Johnson’s government, the bill gives the UK Government powers to dispense of parts of the Northern Ireland Protocol. An announcement on a prospective new agreement between Sunak’s government and the EU on Northern Ireland is expected this week. 


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Open justice, Northern Ireland Protocol and protest rights: The Weekly Round Up 

13 February 2023 by

In the news

  • The Public Order Bill has concluded its Report Stage in the House of Lords and is now due to return to the House of Commons. The Peers voted down several government proposed amendments including those which allowed police powers to (i) pre-emptively shut down protests before any disruption is actually caused; (ii) stop and search without suspicion; (iii) impose Serious Disruption Prevention Orders without conviction. The removal of these amendments does mitigate some of the damage that the Bill threatened to have on the Article 11 right to protest. However, not all amendments were put to a vote and concern prevails about the future impact of the bill. 
  • The UK government has introduced a new amendment to the Social Housing Regulation Bill which enforces time limits within which landlords will have to investigate and fix instances of damp and mould. Tenants will be able to rely on these rules which will be incorporated into tenancy agreements. This new amendment is named “Awaab’s law” after two-year old Awaab Ishak who died from respiratory failure that was caused by a landlord’s failure to resolve mould issues in his home.

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Schrödinger’s Defendants: Inquests, Unlawful Killing and Criminal Acquittals

6 February 2023 by

Three recent cases indicate a substantial change in law and practice, with inquests now seemingly free to make a determination of unlawful killing notwithstanding the acquittal of a defendant at a criminal trial.

The Inquests into the Shoreham air crash

R (Leeson) v HM Area Coroner for Manchester South [2023] EWHC 62 (Admin)

 R (Makki) v HMSC for S. Manchester [2023] EWHC 80 (Admin)

The coronial and criminal jurisdictions have a long and tangled relationship. The word “murder” derives from “murdrum”, the Medieval tax levied on a community after a coronial finding that an unidentified body was that of a Norman. In later centuries, juries at inquests could find people guilty of murder, empowering the coroner to issue an arrest warrant and commit them for trial. Yet from common soil and entwined roots, inquests and trials grew into increasingly distinct plants and during the twentieth century the primacy of criminal investigations and prosecutions became enshrined in legislation. Coroners were required to suspend inquests during criminal proceedings. If resumed, those inquests were prohibited from coming to conclusions that were “inconsistent” with the verdict of the criminal court: see what is now para.8(5) of Schedule 1 of the Coroners and Justice Act 2009 (“CJA 2009”). After 1977, inquests were prohibited from appearing to determine criminal liability on the part of a named person: see what is now s.10(2)(a) CJA 2009. The conclusion of “unlawful killing” remained, but inquests could no longer formally identify who was responsible; that was a matter solely for the criminal courts.


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Strikes, private nuisance, protest Bill: The Weekly Round up

6 February 2023 by

In the news

The Strikes (Minimum Service Levels) Bill has been voted through the House of Commons amidst historic industrial action across the UK. Workers in health, education, transport and the civil service came out on strike in disputes over pay, jobs and conditions, and members of the Fire Brigades Union have voted overwhelmingly in favour of walking out. The synchronisation of strikes across different sectors has seen levels of disruption not seen in at least decades. The government has published a memorandum on the compatibility of the Bill with the ECHR, but the issue is far from clear cut – the Labour party and trade unions have opposed the Bill, and the Joint Committee on Human Rights has put written questions to the Secretary of State. The TUC has not ruled out legal action if the Bill is passed, and February 1st saw nationwide protests on the “right to strike day”.


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A2P1 Aarhus Abortion Abu Qatada Abuse Access to justice administrative court adoption ALBA Allison Bailey Al Qaeda animal rights anonymity appeal Appeals Arrest Article 1 Article 1 Protocol 1 Article 2 article 3 article 3 protocol 1 Article 4 article 5 Article 6 Article 7 Article 8 Article 9 article 10 Article 11 article 13 Article 14 Artificial Intelligence Asbestos Assisted Dying assisted suicide assumption of responsibility asylum Attorney General Australia autism benefits Best Interest Bill of Rights biotechnology blogging Bloody Sunday brexit Bribery Business care orders Caster Semenya Catholicism Chagos Islanders charities Children children's rights China christianity citizenship civil liberties campaigners climate change clinical negligence Closed Material Proceedings Closed proceedings Coercion common law confidentiality consent conservation constitution contempt contempt of court Control orders Copyright coronavirus Coroners costs court of appeal Court of Arbitration for Sport Court of Protection covid crime Criminal Law Cybersecurity Damages Dartmoor data protection death penalty defamation deportation deprivation of liberty Detention diplomatic immunity disability discipline disclosure Discrimination disease divorce DNA domestic violence DPA DSD Regulations duty of candour duty of care ECHR ECtHR Education election Employment Employment Law Employment Tribunal enforcement Environment environmental rights Equality Act Ethiopia EU EU Charter of Fundamental Rights EU costs EU law European Court of Justice euthanasia evidence extradition extraordinary rendition Extraterritoriality Fair Trials Family family law Fertility FGM Finance findings of fact football foreign criminals foreign office Foster France freedom of assembly Freedom of Expression freedom of information freedom of speech Free Speech Gambling Gay marriage Gaza gender Gender Recognition Act genetics Germany gmc Google government Grenfell Hate Speech Health healthcare high court HIV home office Housing HRLA human rights Human Rights Act human rights news Huntington's Disease immigration immunity India Indonesia information injunction injunctions inquest Inquests international law internet interview Inuit Iran Iraq Ireland Islam Israel Italy IVF Jalla v Shell Japan Japanese Knotweed Journalism Judaism judicial review jury jury trial JUSTICE Justice and Security Bill Land Reform Law Pod UK legal aid legal ethics legality Leveson Inquiry LGBTQ Rights liability Libel Liberty Libya Lithuania local authorities marriage Maya Forstater mental capacity Mental Health mental health act military Ministry of Justice Mirror Principle modern slavery monitoring murder music Muslim nationality national security NHS Northern Ireland NRPF nuclear challenges nuisance Obituary open justice Osman v UK ouster clauses PACE parental rights Parliament parliamentary expenses scandal Parole patents Pensions Personal Data Personal Injury Piracy Plagiarism planning Poland Police Politics pollution press Prisoners Prisons privacy Private Property Procedural Fairness procedural safeguards Professional Discipline Property proportionality Protection of Freedoms Bill Protest Protocols Public/Private public access public authorities public inquiries public law reasons regulatory Regulatory Proceedings rehabilitation Reith Lectures Religion Religious Freedom RightsInfo Right to assembly right to die Right to Education right to family life Right to life Right to Privacy Right to Roam right to swim riots Roma Romania Round Up Royals Russia S.31(2A) sanctions Saudi Arabia school Schools Scotland secrecy secret justice Section 55 separation of powers Sex sexual offence sexual orientation Sikhism Smoking social media Social Work South Africa Spain special advocates Sports Sports Law Standing statelessness Statutory Interpretation stop and search Strasbourg Strategic litigation suicide Supreme Court Supreme Court of Canada surrogacy surveillance Syria Tax technology Terrorism tort Torture Transgender travel travellers treaty tribunals TTIP Turkey UK UK Constitutional Law Blog Ukraine UK Supreme Court Ullah unduly harsh united nations unlawful detention USA US Supreme Court vicarious liability voting Wales war War Crimes Wars Welfare Western Sahara Whistleblowing Wikileaks Wild Camping wind farms WINDRUSH WomenInLaw World Athletics YearInReview Zimbabwe