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UK Human Rights Blog - 1 Crown Office Row
Search Results for: environmental/page/46/Freedom of information - right of access) [2015] UKUT 159 (AAC) (30 March 2015)
Denise McDonagh v Ryanair Ltd [2013] EUECJ C-12/11 (31 January 2013) – read judgment
“Congratulations! You have arrived on yet another ontime Ryanair flight. Ryanair – for the lowest fares and the best ontime record. Outstanding”
… or maybe not so outstanding.
On 11 February 2010, Ms McDonagh booked a flight with Ryanair from Faro (Portugal) to Dublin (Ireland) scheduled for 17 April 2010. On 20 March 2010, the Eyjafjallajökull volcano in Iceland began to erupt. On 14 April 2010, it entered an explosive phase, casting a cloud of volcanic ash into the skies over Europe. On 15 April 2010, the competent air traffic authorities closed the airspace over a number of Member States because of the risks to aircraft. Ms McDonagh’s flight was cancelled following the closure of Irish airspace. Ryanair flights between continental Europe and Ireland resumed on 22 April 2010 and Ms McDonagh was not able to return to Dublin until 24 April 2010. In the intervening week, no efforts were made by the airline to provide Ms McDonagh with the care to which she was entitled under the relevant EU Regulation No 261/2004, providing rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights. Continue reading →
These are the words that Hayden J, Vice President of the Court of Protection, used to describe AH, the applicant in this case. The Official Solicitor identified it as “the most troubling and tragic of cases of this kind” with which she has been involved.
This case is the most recent and cogent in the consideration of best interests under the Mental Capacity Act in terms of continuing life-saving treatment. The “best interests” test is laid out in Aintree University Hospital NHS Trust v James [2013] UKSC 67.
AH’s family was originally from Pakistan. She and her family moved to Uganda but they were expelled, as South Asian residents, under the Idi Amin regime, in the early 1970’s. AH’s medical history showed signs of non-specific arthralgia, raised calcium levels and Type 2 diabetes. She had been diagnosed with carpal tunnel syndrome. She did not smoke, nor did she drink alcohol.
In early January 2020 she suffered a high fever which her doctors identified symptomatic and not causative of the cytokine/autoimmune ‘storm’ which created the “devastating” neurological damage and the pathological processes she has suffered from since. Both her treating doctors had seen similar cytokine ‘storms’ in patients critically ill with Covid-19 although neither has seen damage as extensive as that sustained by the applicant. All agreed that it was in consequence of this ‘storm’ that there had been such “extensive damage” to the nerves and to the muscle as well as to the brain.
At first sight, Article 2 – the ‘right to life’ – seems to be a prohibition on extra-judicial executions and state-sponsored death squads. It does, of course have a role to play in that respect (and one that is not limited to those countries whose signature of the Convention is viewed with scepticism from Western Europe).
But through a combination of logic, inventive legal argument and what can either be characterised as the incremental development of a new area of law, or the expansionist tendencies of Strasbourg judges, the scope of Article 2 has broadened significantly, and can be cited in cases concerning prison administration and coronial procedural law.
In Rabone, the Supreme Court extended the obligations that the Article places on the state and its servants still further, beyond even the existing decisions from Strasbourg. They held that – in the specific circumstances of this tragic case – an NHS Trust had violated the positive duty that it had, under Article 2, to protect a voluntary patient from the risk of suicide.
CD v ST (judgment of the Court) [2014] EUECJ C-167/12 (18 March 2014) – read judgment
Z v A Government Department and the Board of Management of a Community School C‑363/12 – read judgment
The European Court (CJEU) has now considered two requests for preliminary ruling made in proceedings between intended mothers (also referred to as a commissioning mother) who have had babies through a surrogacy arrangement, and their employers concerning the refusal to grant them paid leave following the birth of the babies. It has replied that EU law does not provide for commissioning mothers to be entitled to paid leave equivalent to maternity leave or adoption leave.
I reported on the AGs’ opinions in both cases here, noting that AG Kokott and AG Wahl took a completely different approach in their interpretation of the applicability of Directive 92/85 in surrogacy cases; the Court has clearly decided that granting maternity leave in these circumstances would be a step too far.
Lumba (WL) v Secretary of State for the Home Department [2011] UKSC 12 (23 March 2011) – Read judgment / press summary
The Supreme Court has ruled that it was unlawful and a “serious abuse of power” for the Home Office to follow an unpublished policy on the detention of foreign national prisoners which contradicted its published policy. Two convicted prisoners were therefore unlawfully detained.
This fascinating 6-3 majority decision could be important in respect of setting the boundaries for the courts’ scrutiny of executive powers. It is also, for the record, not a decision which is based on human rights. The appellants are both convicted criminals (and foreigners too), so the court may be criticised for upholding their human rights despite their criminal actions. But this is a case decided on traditional public law grounds, which preceded the human rights act by many years. As Lord Hope put it:
Laura Profumo brings us the latest human rights goings on.
In the News:
This afternoon, the new Conservative Government’s legislative plans were announced in the Queen’s Speech. Michael Gove, the recently appointed Justice Secretary, will have to defend his party’s intention to scrap the Human Rights Act, blunting the influence of Strasbourg jurisprudence. As Daniel Hannan observes, Gove faces a “different order of magnitude” in his new role, finding himself up against an “articulate and wealthy lobby” within the legal profession. An “elegant compromise” might be found, Hannan suggests, in amending our extant Bill of Rights to include ECHR freedoms, restoring “our sovereignty and our democracy”.
It is certainly clear that Gove will have to carefully pilot the reforms through Parliament. Lord Falconer cautions that the House of Lords, where the Conservatives don’t have a majority, may prove obstructive:
“If the Conservative measures strike at fundamental constitutional rights, the Lords will throw this back to the Commons”.
The backbencher minority of ‘Runnymede Tories’, forcefully headed by David Davis, will also seek to stall the Bill’s course. Yet, Matthew d’Ancona concedes, “if anyone has the intellectual firepower to square all the circles it is Gove”.
In brighter news, the Republic of Ireland has become the first country to legalise same-sex marriage through popular vote. Some 62% of the electorate voted in favour of the reform, with all but one of the Republic’s 43 constituencies voting Yes. The result comes just two decades after the Irish government decriminalised homosexuality, marking a milestone in Ireland’s divisive religious history. The Archbishop of Dublin, Diarmuid Martin, recognised the vote as a “social revolution”, which requires the Church to “have a reality check, not move into the denial of realities”.
In a prelude to the historical referendum, the ‘Gay Cake’ Case, which has gripped Northern Ireland for the last year, come to a close last week. In a clear decision, it was found that the Christian bakery’s refusal to make a campaign cake the LGBT support group, QueerSpace, amounted to direct discrimination on grounds of sexual orientation. The outcome has not been welcomed by all. TUV leader Jim Allister lamented it a “dark day for justice and religious freedom”, whilst Melanie McDonagh, writing in the Spectator, found the decision inversely “intolerant and discriminatory”, forcing a Presbyterian business to promulgate a message “at odds with their belief”. Yet talk of religious persecution is besides the point, argues academic Colin Murray. The case concerned the “ability to do the banal and ordinary things in life without these activities becoming the subject of public opprobrium”. It was not, as McDonagh suggests, a case of cake artisans’ ‘right to ice’, but the right of the public to lawfully contract with a business, irrespective of “how that public is constituted”.
Following the decisive vote across the border yesterday, many hope that Northern Ireland, the only part of the United Kingdom where same-sex marriage is still prohibited, will follow suit. Deputy First Minister Martin McGuinness has advocated a referendum: “This is a matter of whether or not we want to live in a modern progressive society that respects minorities”. Now that Northern Ireland has their cake – it remains to be seen whether the idiom will ring true.
In Other News:
Haile v London Borough of Waltham Forest: The Supreme Court ruled that the appellant had not made herself intentionally homeless when, after learning that she was pregnant, she left her London hostel. As she would have been evicted from the hostel anyway, on giving birth to her child, the Court ruled in her favour. Her lawyer, Nathaniel Matthews, welcomed the decision as one in which “glorious common sense prevailed. Women who become homeless because they have become pregnant must be protected”.
Vladimir Putin has signed a bill which allows foreign NGOs to be banned from operating in Russia. The law will allow authorities to prosecute NGOs which are designated as ‘undesirable’ on national security grounds. Individuals working for such organisations could face fines, or up to six years’ imprisonment. Amnesty International has condemned the measure as part of the “ongoing draconian crackdown…squeezing the life out of civil society”.
In the Courts:
Identoba and Others v GeorgiaThe Georgian police failed to protect participants in a march against homophobia from violent attacks of counter-demonstrators. ECtHR held the police had violated the protestors’ Article 3 and 11 rights, in failing to take sufficient measures to prevent the attacks.
SS v the United Kingdom; F.A and Others v the United Kingdom A case concerning convicted prisoners’ entitlement to social security benefits was held to be inadmissible by ECtHR. The applicants were prisoners in psychiatric hospitals who complained that, under new 2006 regulations, denying them benefits paid to the other patients amounted to unjustified discrimination. The Court emphasised Contracting States’ margin of appreciation in social policy, finding that the differential treatment was not unreasonable, given that the applicants, whilst patients, were also convicted prisoners.
Gogitidze and Others v Georgia The ECtHR ruled that the forfeiture of a wrongfully acquired property was not in breach of the tenant’s right to peaceful enjoyment of their possessions, under Article 1 of Protocol No.1. As the property confiscated belonged to the former Deputy Minister of the Interior, the Court inquired whether a proportionate balance had been struck between the method of forfeiture and the public interest in combating political corruption. The domestic courts were held to have achieved such a balance.
Events:
‘Do we need a new Magna Carta?’ The Miriam Rothschild & John Foster Human Rights Trust, and University College London, are hosting a lecture given by Lord Lester QC, on alternatives to the embattled Human Rights Act. The event will take place at 6.15pm, 15th June, at the Institute of Child Health. Please RSVP to rsvplectureinvitation@gmail.com.If you would like your event to be mentioned on the Blog, please email the Blog’s Commissioning Editor, Jim Duffy, at jim.duffy@1cor.com
New legislation significantly curtails accommodation provision for those seeking release from immigration detention. The likely result is more and more people being held in immigration detention.
The fight to end to indefinite detention of immigrants pending their removal from the UK has been gathering momentum. There have been parliamentary debates and expert reports, all critical of the Home Office policy of what effectively involves ‘warehousing’ immigrants in cramped and often unsafe conditions with no end in sight.
While there is no legal maximum for how long someone can be held in immigration detention, the Home Office can only use their power to detain if they intend to remove the person and can do so ‘within a reasonable period’. If at the outset it is apparent that the person cannot be removed within a reasonable period they should not be detained at all. If it becomes apparent once detention has commenced that the person cannot be removed within a reasonable period, then the person should also be released. In addition, the Home Office should exercise appropriate diligence in their efforts to remove the person.
Despite these well-established restrictions on the power to detain, men and women are still held in detention centres for extended periods of time. In March 2018, a report by HM Inspectorate of Prisons of Harmondsworth Immigration Removal Centre found that 23 men had been held for over year, and one man had been held for four years.
Do they have anything in common? Relatively little, says Nicola Barker, Professor of Law at the University of Liverpool.
When the IHRAR was announced by Robert Buckland in December 2020, it was accompanied by some of the usual rhetoric about the courts “rewriting” legislation, but the more hyperbolic claims about foreign criminals and pet cats were absent. The Terms of Reference given to the IHRAR were relatively narrow and the Call for Evidence emphasised that it was ‘not considering the substantive rights set out in the Convention’. Instead, the Review was to focus only the operation of the HRA under two themes: the relationship between domestic courts and the ECtHR; and the impact of the HRA on the relationship between the three branches of the state.
However, in its consultation document, the government’s language once again carries echoes of the pet cat oeuvre with a stance premised on the idea of a ‘broader public interest’ that must be ‘safeguarded’ (para 182) from the HRA. In this, they are articulating a problem that lies not so much with the HRA’s impact on the separation of powers and Parliamentary sovereignty (though those remain too) but with ‘the way in which [Convention] rights have been applied in practice’ (para 184). In other words, the focus is back on how to prevent rights from benefitting the ‘undeserving’ and how to forestall further development of rights through the ‘living tree’ doctrine.
Given that the Review was only commissioned a year ago it is unfortunate to see several reforms proposed in the government’s consultation that could have usefully been included within the remit of the Review but were omitted from the Terms of Reference, not least the proposals in relation to section 6. The government propose to expand the exception in section 6(2)(b) (that applies where a public authority was giving effect to primary legislation that could not be read or given effect in a way that is compatible with Convention rights) to include circumstances where the public authority is giving effect to the clear intentions of Parliament (para 274). This proposal is based on the premise that section 6 has created ‘confusion and risk aversion for frontline public services’ (para 132-140) and undermined public protection as the police and armed forces ‘find operational decisions challenged’ and ‘have a court retrospectively second-guess their professional judgement exercised under considerable pressure’ (para 142). It is regrettable that the Review was not able to consider the accuracy of the premise underlying such potentially far-reaching reforms, which could significantly undermine individual rights protection in the UK.
The more substantive questions of the balance between speech and privacy, between rights and responsibilities, limiting access to Convention rights in the context of deportation, and whether a specific right to jury trial is necessary, could also have been usefully informed by the extensive research, in-depth discussion with a variety of stakeholders, and objective analysis that were characteristic of the Review.
The table below maps the government’s proposals for a new Bill of Rights on to the recommended and not recommended/rejected options in the IHRAR report. The government makes around 40 proposals, though some present alternative options rather than separate and distinct proposals. Green text indicates where the government’s proposals broadly match a recommendation of the IHRAR, while red text indicates that the government are proposing something that the Review explicitly or implicitly cautioned against. Sometimes the proposals do not map in exactly the terms recommended or rejected by the Review, but I have matched them as closely as possible with the language used by each. For example, where the government proposals refer to ‘enabling’ UK courts to take account of case law from other jurisdictions and international bodies (a power they already can and do exercise), the Review did not consider affirming this existing power but rejected ‘requiring’ them to consider such case law. As the table illustrates, the government’s proposals bear little resemblance to the recommendations made by the IHRAR panel. More of the government’s proposals are ideas that were rejected by the Review than were recommended by it and around half of the government’s proposals were not considered by the Review at all, in most cases because they were outside of its Terms of Reference.
The Independent Review recommended first, and in my view most importantly, that there should be more public education about the UK constitution and HRA in schools, universities, and adult education. The Review itself could form the basis of that education. It is a thorough and clear exposition of the Act, its interpretation and use by the Courts, and its impact on the separation of powers, Parliamentary sovereignty, and the relationship between the UK and Strasbourg. However, the government appears to have ignored this recommendation and in general the Review appears to have asserted little influence on the government’s proposals.
Gurung v Secretary of State for the Home Department [2012] EWCA Civ 62 (02 February 2012) – read judgment
In a short but fascinating judgment which lays bare the foundation stones of judicial review, the Court of Appeal has articulated the principles to be applied when considering whether automatic deportation of a foreign criminal was “proportionate” for the purposes of Article 8 of the Convention.
This was an appeal by the secretary of state against a decision of the Upper Tribunal (UT) that the deportation of the respondent (G) would interfere with his family life. The respondent had arrived in the United Kingdom in 2005 to join his father who had been granted indefinite leave to remain in the United Kingdom at the end of his service with the Gurkhas. Shortly afterwards G was involved in a group attack on a man, which led to the unconscious victim being thrown into the Thames and drowned. G was subsequently tried and convicted of manslaughter, which meant that he was subject to automatic deportation under the UK Borders Act 2007. However, the Upper Tribunal found that automatic deportation would be a disproportionate interference with his right to family life in the UK. Continue reading →
Mousa and others, R (on the application of) v Secretary of State for Defence [2013] EWHC 2941 (Admin) – read judgment
A postscript to Rosalind English’s post of today. In the substantive judgment (see Adam Wagner’s post on the order), the Divisional Court decided two main issues, one relating to the independence of the Iraq Historic Allegations Team, and one relating to the extent to which an inquiry conducted through IHAT complied with Article 2 of the ECHR. The Secretary of State succeeded on the first issue, whereas the claimant succeeded substantially on the second issue relating to the need for a different form of inquiry. Hence there was no overall winner; the Secretary of State won on the first issue and the claimant succeeded substantially on the second issue. But more time was spent on the first issue.
What then to do about costs? And why is that interesting – promise you, it is important.
Medical experts have claimed that Lucy Letby did not murder any babies at the Countess of Chester Hospital, concluding that the infants died of natural causes and negligent medical care. Having reviewed the medical evidence, a panel of 14 world-leading neonatologists have concluded that they “did not find any murders”. The case has been submitted to the Criminal Cases Review Commission in light of what Letby’s legal team described as overwhelming evidence of a miscarriage of justice. Letby is currently serving 15 whole-life prison terms having been convicted of murdering seven babies. Two previous attempts to challenge her convictions at the Court of Appeal have been dismissed. The CCRC is expected to review the panel’s full report in the coming weeks. If it is decided that there is a real chance of quashing the convictions, the CCRC can send the case back to the Court of Appeal.
Master of the Rolls, Sir Geoffrey Vos,has urged lawyers and judges to embrace generative artificial intelligence at the LawtechUK Generative AI event for three reasons. First, the industrial, financial and consumer sectors, which lawyers serve, will be using it “at every level”. Second, lawyers are going to be “at the forefront of AI liability disputes” in the coming years with regard to the negligent or inappropriate use of AI, and if lawyers do not master the capabilities and weaknesses of AI they will not be able to advise clients properly. Finally, it will save time and money and engender greater efficiency. Vos expressed irritation towards those who use “silly examples of bad practice as a reason to shun the entirety of a new technology” and stressed that there is nothing “inherently problematic with AI”. Rather, it is a question of understanding what AI is doing and using it appropriately. Ultimately, for Vos, it is “uncontroversial” that lawyers should be using AI to “promote and improve access to justice and the quality of decision-making”.
In International News
China has unveiled tariffs on the United States in response to the 10% levies that President Trump recently imposed on China. China has justified its retaliatory tariffs by arguing the United States’ levies violated WTO rules, damaging economic and trade cooperation between the two countries. Trump contended that the imposition of Chinese tariffs is a response to trade deficits, and the flow of fentanyl into the US. Whilst Trump postponed the 25% levies imposed on Canada and Mexico for one month, no such postponement measures were enacted in the case of China. The levies have caused significant volatility in the global financial markets. Trump has suggested that he would pursue similar action against the EU but that a deal could be “worked out” with the UK. The UK now needs to decide if it aligns itself with the EU or the US, or neither. If the UK aligns itself more closely on trade with the EU, this will likely entail accepting the EU’s regulations on agriculture and food safety. However, the United States’ standards in such areas differ significantly from those of the EU. If the UK were to adopt EU agricultural standards, this may make a UK-US trade deal much harder given that the US would likely not want an agreement that excludes agriculture. This is at the same as the EU are wrangling with the UK over a closer relationship going forward. Key issues pertain to the youth mobility scheme (a priority for Germany) and an extension to current fishing rights arrangements (a priority for France). In the next few weeks, we may get clarity as to how the UK chooses to position itself between major global trading blocs.
In the Courts
The Court of Appeal has allowed an appeal over whether a local authority which has ‘corporate’ parental responsibility for a child under the age of 16 can consent to the deprivation of their liberty. The case concerns a 14 year old disabled boy known as ‘J’ who is ‘looked after’ under S.20 of the Children Act 1989 and who resides in a specialist children’s home. In J: Local Authority consent to Deprivation of Liberty, Re [2024] EWHC 1690 (Fam), Lieven J held that a local authority could deprive J of his liberty and did not need the court’s approval to do so. This was because the decision the local authority was being asked to make under S.33(3)(b) of the Children Act 1989 was not of “such magnitude” that the Court would need to make it instead. For Lieven J, depriving J of his liberty was “essential to ensuring his best interests” so necessarily fell “within the LA’s statutory powers” under S.33 of the Children Act [34]. All parties in the case felt that the local authority should not deprive J of his liberty without the court’s approval. The interveners (Article 39 and Mind, the Secretary of State for Education and the Children’s Commissioner) also supported court oversight. With a panel comprising the President of the Family Division, Sir Andrew McFarlane, Lady Justice and Lord Justice Singh, the Court of Appeal confirmed the appeal was successful and made a deprivation of liberty order, with full reasons due to be provided at a later date. Consequently, Lieven J’s ruling should not now be followed.
Q v Q ; Re B (a child) ; Re C (a child) [2014] EWFC 31 – 6 August 2014 – read judgment
Public funding is not generally available for litigants in private-law children cases, and no expert can now be instructed in such a case unless the court is satisfied, in accordance with section 13(6) of the Children and Families Act 2014, that the expert is “necessary” to assist the court to resolve the proceedings “justly”. As the President of the Family Division observed, restrictions on legal aid in certain circumstances has led to a “drastic” reduction in the number of legally represented litigants:
The number of cases where both parties are represented has fallen very significantly, the number of cases where one party is represented has also fallen significantly and, correspondingly, the number of cases where neither party is represented has risen very significantly.
All this has led to increased calls on the Bar Pro Bono Unit, which is generally not able to meet the demand.
Sir James Munby P has therefore suggested that the cost of certain activities, such as bringing an expert to court and providing advice to parents accused of sexual offending within the family, should be borne by the Courts and Tribunals Service. Continue reading →
Koldo Casla of the Policy, Research and Training Manager of Just Fair @JustFairUK, an organisation that monitors and advocates economic and social rights in the UK
Women’s sexual and reproductive rights are not safe and accessible in all corners of the United Kingdom: see Rosalind English’s post on the Northern Irish situation here and here.
Update: the government has announced its intention to make funding available for women travelling from Northern Ireland to have free termination services on the NHS in England (29 June 2017).
Abortion is still a crime in Northern Ireland. Women who choose to exercise their sexual and reproductive rights have to travel to mainland Britain, but they have to face costs (about £900 in the recent case discussed by Rosalind English) that would not apply if they lived in England, Wales or Scotland.
By a majority of 3 to 2, the Supreme Court ruled that, while this situation does in principle concern the right to enjoy a private and family life without discrimination (Articles 8 and 14 of the European Convention on Human Rights), the difference in treatment is justified because the decision on this matter falls under the powers of the devolved administration of Northern Ireland (paragraph 20 of the Judgment). And therefore the human rights of women living in Northern Ireland are not being breached. Continue reading →
Begum v Special Immigration Appeals Commission and the Secretary of State for the Home Department[2020] EWCA Civ 918
Early last year, after ISIL was dislodged from Raqqah, Shamima Begum was discovered in a refugee camp in Syria. When she expressed a wish to return home to London’s Bethnal Green, Her Majesty’s Government wasn’t welcoming. She had left to join ISIL and HMG did not want her back. It considered her a serious risk to national security and removed her British citizenship. It then refused her leave to enter the UK to appeal that decision. But the Court of Appeal, in the latest legal ruling on the case, has held that fairness requires she be permitted to return to participate in her appeal.
The Court’s decision overturns some, but not all, of the Judgment of the Special Immigration Appeals Commission (SIAC) delivered in February (and reported here).
P (A Child) [2014] EWCA Civ 888 – read judgment here.
1 Crown Office Row’s Martin Downs represented the parents in this appeal (not at first instance), but is not the author of this blog post.
In this successful appeal against care and placement orders in respect of a young infant with Polish parents, the Court of Appeal were sharply critical of comments made by the first instance judge which made it clear he had closed his mind at an early stage to the possibility of the baby being looked after by her grandparents in Poland. The Court held that both the judge and the local authority had failed to give sufficient weight to their positive obligation under Article 8 to consider ways of retaining a child within the family.
The parents in this case were Polish nationals who moved to England in 2011. Their daughter was born in September 2012. For the first five-and-a-half months of the little girl’s life, there were no concerns about the care she was receiving from her parents. However, in February 2013 she was taken to her local hospital in Warrington with a head injury which was found to be non-accidental and probably inflicted by the father. On discharge from hospital the baby was taken into foster care. Proceedings were instituted and after several hearings before HHJ Dodds concluded in December 2013 with an adoption placement.
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Denise McDonagh v Ryanair Ltd [2013] EUECJ C-12/11 (31 January 2013) – read judgment
Rabone and another v Pennine Care NHS Foundation Trust [2012] UKSC 2 – 
Lumba (WL) v Secretary of State for the Home Department [2011] UKSC 12 (23 March 2011) – 
New legislation significantly curtails accommodation provision for those seeking release from immigration detention. The likely result is more and more people being held in immigration detention.
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