Immigration – Deportation. The claimant Jamaican national had an extensive criminal history of serious offending in the United Kingdom. He sought judicial review of the defendant Secretary of State's decision to certify his case, under s 96 of the Nationality, Immigration and Asylum Act 2002, in the context of her principal decision to refuse to revoke the claimant's deportation order. The Administrative Court, in dismissing the application, held that the Secretary of State had been entitled to take the approach she had to the issue of certification, even in the light of allegedly substantial developments or changes in the law.