Armed forces – Service complaints. The first defendant Army Board of the Defence Council (the panel) rejected the claimant's service complaint, contending that his career had been mismanaged. The claimant issued judicial review proceedings. The Administrative Court, in dismissing the application, held that the panel had been entitled to take the view that an oral hearing had not been necessary to fairly decide the matter. Further, the 34-month delay in the determination of the complaint had not been unlawful under art 6 of the European Convention on Human Rights or at common law.