Human rights – Right to liberty and security. The Mental Health Act 1983 did not give a responsible clinician the power to impose conditions which had the concrete effect of depriving a community patient of his liberty, within the meaning of art 5 of the European Convention on Human Rights. The Supreme Court so ruled in allowing an appeal by an appellant who had argued that the arrangements under a community treatment order amounted to an unlawful deprivation of his liberty and that he should, therefore, be discharged from it.