Police – Complaints against police. The Metropolitan Police Commissioner issued judicial review proceedings, seeking to quash an Independent Police Complaints Commission's (the IPCC) decision to reopen the investigation into D's allegation he had been strangled during his arrest, on the basis it was functus officio. D sought to quash the conclusions found in the IPCC's original report. The Divisional Court held that the IPCC had power to seek further information in respect of a report it considered defective. Further, errors of reasoning in the report rendered it irrational. Accordingly, the Commissioner's claim would be dismissed, but D's claim would be allowed.