R (on the application of Hovenden) v Parole Board

Sentence – Imprisonment. The claimant serial sex offender sought judicial review of the defendant Parole Board's decision that his continued confinement in prison was necessary for the purposes of public protection. He contended that, despite the Parole Board's correct application of the public protection test in its conclusion, the opening paragraph of its decision revealed that it had applied the wrong test. The Administrative Court, in dismissing the application, held that the Parole Board's conclusion had been actuated by the correct test as set out in the final paragraph and that it had plainly applied the correct public protection test.