Police – Complaint against police. In the course of litigation following 'Plebgate', the claimant police officers sought judicial review of the Independent Police Complaints Commission's decision to re-determine the mode of investigation of them. The Divisional Court found that, as a result of procedural irregularities, the report of the original investigation had been invalid and of no effect. The argument that the power to re-determine the mode of investigation had not been available could not succeed, but there had been apparent bias or predetermination in that decision.