R (on the application of Hodge) v Information Commissioner

Practice – Civil restraint order. Since 2008, the claimant serving prisoner had commenced 13 separate unmeritorious judicial review claims and six separate private civil claims on a range of subjects concerning his imprisonment. He applied to discharge an extended civil restraint order (ECRO) made against him and the Secretary of State applied for the ECRO to be converted into a general civil restraint order (GCRO). The Administrative Court held that, as the claimant was not obsessed with one theme, but several themes concerning his imprisonment, an ECRO was unlikely to be effective. Accordingly, the appropriate and proportionate response was to make a GCRO.

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