The design of Brook House and its facilities

Design of Brook House

Figure 29: Aerial view of Brook House

Source: Financial Times, 14 September 2017

3. The Home Office was responsible for the design and construction of Brook House. The physical environment was described by many witnesses as unfit for purpose as an immigration removal centre (IRC) holding detained people for more than a few days.
4. It was accepted by G4S that Brook House was “built to the specifications of a Category B prison albeit without the education facilities and space for activities that would be available in such a prison”.¹
5. Mr Philip Riley, Director of Detention and Escorting Services (DES) within the Home Office, did not agree that it was designed as a Category B prison, but his reasons related to its culture and regime rather than the building itself.² By contrast, in a 2019 judgment, the High Court described Brook House as having been “modelled on the design of a category B prison”, as did a report by HMIP following a March 2010 inspection.³
6. In his 2016 report for the Home Office on the welfare of vulnerable people in immigration detention, Mr Shaw described Brook House as “prison- like in aspect and in terms of security” and observed that it had “a small footprint meaning the facilities are rather cramped”.⁴ He was concerned that the introduction of anti-suicide safety netting had added to the oppressive environment.⁵ He also had some concerns about the multi-purpose use of E Wing to manage detained people with varying needs.⁶ This was a concern that he was to repeat when he returned to Brook House for a 2018 follow-up report.⁷

Figure 30: Safety netting at Brook House

7. In 2018, Ms Sarah Newland, Head of Tinsley House during the relevant period (1 April 2017 to 31 August 2017), and subsequently Deputy Director of Brook House and Tinsley House (Gatwick IRCs), remarked:

“Brook House is ostensibly a prison. It is built like a prison – it is prison wings. I think the whole environment that that brings, the acoustics, the noise, the numbers can be really overwhelming for people who haven’t experienced it before.”⁸

8. Mr Ben Saunders, Centre Director for Gatwick IRCs during the relevant period, described Brook House as:

“a much harsher environment [than Tinsley House], it was designed more like a prison and it felt like a prison. There were four main wings and a much smaller one designed for more vulnerable and challenging individuals. It was a far more oppressive building which we tried to soften but there is only so much you can do with the existing infrastructure.”⁹

9. Monitoring bodies were also highly critical of the environment

9.1 In its report following a May–June 2013 inspection, HMIP stated that “Despite efforts to soften the environment, the centre continued to look and feel like a prison” and made a recommendation that plans “to soften the environment should be implemented across the centre”.¹⁰

9.2 This was reiterated in the October–November 2016 HMIP inspection report, when it made recommendations concerning the poor ventilation and unsatisfactory sanitary conditions.¹¹ When asked about the so-called “mis-design” of Brook House, Dr Hindpal Singh Bhui, Inspection Team Leader at HMIP, stated that holding immigration detainees in a centre designed as a Category B prison was “inappropriate” and that they should not be accommodated in “prison-like environments”.¹²

10. There was limited outside space. As noted by Professor Mary Bosworth, the Inquiry’s cultural expert, “the category B design … comes with a couple of concrete yards, and there’s … not enough space”.¹³ Due to its prison specification, Brook House was surrounded by tall razor wire fencing.¹⁴ This must have added to the oppressive feeling for detained people. The prison-like environment was harmful and inappropriate for all detained people, even for those who had served a prison sentence, particularly given the problems with overcrowding and with the facilities discussed in this chapter.
11. There was also some dispute about whether Brook House was only ever designed to hold people for 72 hours. Mr Riley described this as “patently incorrect” and an “urban myth”.¹⁵ However, the 2010 HMIP inspection report on Brook House noted that “The centre was designed to hold detainees for no more than 72 hours” and also that there was an “erroneous assumption that detainees would be staying only a few days”.¹⁶ G4S senior management and senior managers within Brook House suggested that it was designed for very short-term stays.¹⁷ In addition, the bids to manage Brook House, the assessment of those bids and the assumptions set out in the G4S contract appeared to be premised on the basis that people would be detained there for a matter of days.¹⁸
12. I think it likely that Brook House was initially designed to hold detained people for no more than a few days, but that it became clear fairly soon after it opened that, in practice, most detained people stayed for much longer periods.¹⁹ Despite this, no significant changes were made to the building or how it was used for things such as activities and education.
13. In its first report (for April 2009–March 2010), the Independent Monitoring Board at Brook House (Brook House IMB) expressed “great concern” that at least five detained people had been held for nearly a year. The Brook House IMB also noted that the design of Brook House did “not allow for many activities to occupy the men held there” and therefore they “should not be held for an extended length of time”.²⁰ It also noted that “the design of the Centre is not adequate for detainees to be held for any protracted length of time”.²¹ Similarly, HMIP noted in its 2010 inspection report:

“There had been limited investment in activity places as Brook House had been designed on the assumption that detainees would stay for only a short time before removal or release. In reality, many stayed for lengthy periods.”²²

14. The proportion of people detained at Brook House for less than a week has ranged from 11.7 per cent in 2010 to 23.3 per cent in 2017 and to 9.9 per cent in 2022.²³

Conditions inside Brook House

15. The prison-like, short-term specification for Brook House had consequences for the environment in which detained people lived.
16. Professor Bosworth commented:

“The design of Brook House Immigration Removal Centre is inappropriate for its purpose. The half doors of showers are undignified, while the toilets in the bedrooms and the inability to open the windows create unpleasant living spaces. Men on the footage … report that their living spaces became uncomfortably hot in the summer months. These claims are reinforced by details in the IMB minutes. There is limited access to natural light and outdoor space as well as only a small area for activities. The daily schedule is punctuated by roll calls during which men are locked back in their rooms.”²⁴

Cells

17. Detention Custody Officer (DCO) Callum Tulley told the Inquiry that most DCOs referred to detained people’s rooms as cells since they “were so obviously cells”.²⁵ They were small, with two single beds. There was no handle on the inside of the door which would enable detained people to leave freely, the window was unopenable, and there was a toilet in the cell that caused it to smell.²⁶

Figure 31: Cell at Brook House

18. There was a toilet with a privacy screen (a waist-high partition) and sometimes a curtain (although this was not always available) that separated the toilet from the rest of the cell.²⁷ Detained people vividly described the humiliation they felt about having to use the toilet in front of their cell mates.²⁸ Mr Tulley told the Inquiry that he would visit cells with unscreened toilets “on a weekly if not daily basis” and that detained people would often complain to him about the smell in their cells and the lack of fresh air after they had been locked in for long periods of time.²⁹ It was humiliating for detained people to use the toilet without a curtain in very close proximity to others, particularly where the ventilation was poor. There was no reason why, at the very least, adequate partitions could not have been provided between the toilet and the rest of the cell.
19. HMIP highlighted these and other issues about poor conditions in every inspection report since 2010 (discussed in Chapter D.11). Following its 2016 inspection, one of HMIP’s main recommendations was that:

“Concerted action should be taken to soften the prison-like living conditions. Showers and toilets should be adequately screened, and toilets deep cleaned. Units should be well ventilated and detainees should have more control over access to fresh air.”³⁰

20. The lack of ventilation in cells was described in 2018 as the “chief complaint among detainees” by Mr Jeremy Petherick, Managing Director of G4S Custodial and Detention Services.³¹ In his evidence to the Inquiry in March 2022, Mr Petherick said that “we were doing our best to alleviate many of the inherent problems” with the design of the building, which included unopenable windows.³² Mr Lee Hanford, Business Change Director at G4S during the relevant period, also recognised that ventilation was an “issue” even before the introduction of 60 additional beds.³³ He said that the windows were worse than prison windows because prison windows had a “triple vent”. The Brook House windows did not have such vents in order to reduce the sounds from Gatwick Airport, which is located next to Brook House.³⁴ Mr Petherick, in his evidence to the Inquiry, stated that the toilets were difficult to clean because their construction materials required particularly abrasive chemicals to be used (cleanliness had to be balanced against the health risks associated with the use of those cleaning materials).³⁵
21. However, the Inquiry heard no evidence that specific action was taken by G4S in response to HMIP’s recommendations. Poor conditions remained during the relevant period. Issues with the lack of ventilation and unscreened and unclean toilets in small cells, partly a product of the prison-like design, led to humiliating experiences for many detained people.
22. Many witnesses also referred to the internal noise levels, with the banging of heavy doors putting people “on edge”.³⁶ The noise inside Brook House was obvious from the Panorama programme. There was also external noise. Professor Bosworth noted:

“Brook House is right next to the runway at Gatwick, so it’s extremely noisy, you hear the planes landing and taking off all the time. It’s a very, very harsh environment to be in.”¹³

The proximity to Gatwick Airport and the noise impact on detained people were also noted by a local authority planning officer in 2006, who stated that “insulation of the development has been agreed with colleagues in the Environmental Health Division based upon limited time occupation of the building by individual detainees”.³⁷

23. In its Closing Statement to the Inquiry, the Home Office conceded that standards of cleanliness and hygiene at Brook House during the relevant period were “not acceptable”.³⁸ It highlighted the fact that G4S’s Service Improvement Plan (in response to HMIP’s 2017 recommendation) was partially accepted due to the limitations of the building design.³⁹ This was because the building management system did not allow for individuals to control air access in their cells.⁴⁰ However, the plan stated that a review of the effectiveness of the ventilation system would take place (with a time frame of six months) and that a “continuous programme of cleaning” cells and toilet areas was being implemented.⁴¹ Mr Riley pointed to improvements made since the relevant period, which include a cleaning and maintenance programme, refurbishments and redecorations commencing in October 2017, and improvements to toilet and shower screening.⁴²
24. Despite these actions, HMIP has remained critical of the current environment provided to detained people under Serco’s management of Brook House from May 2020. The May–June 2022 HMIP inspection report stated that a “priority concern” was that:

“The centre did not provide an open or relaxed environment suitable for immigration detainees. The centre was crowded and noisy, ventilation in cells was inadequate and the prison-like environment was one of the main reasons that detainees gave for feeling unsafe.”⁴³

Increases in the capacity of Brook House

25. The capacity of Brook House was increased in March 2013 by 22 beds, from 426 to 448 beds.⁴⁴ Mr Petherick told the Inquiry that these additional beds were added not to increase profits but “to increase operational efficiency”, for example by having a pre-departure unit and increasing the number of cells designed for constant watch.⁴⁵ I did not find this explanation convincing. A 360-degree contract review produced by Mr Saunders in June 2014 demonstrated that G4S did make an additional profit of £28,000 per year by adding the extra beds.⁴⁶ Mr Petherick also told the Inquiry that it did not necessarily follow that staffing would increase as a result, and that he feltthat the staffing ratios remained appropriate following the increase in beds.⁴⁷
26. In 2014, the Home Office requested an increase in the population at Brook House. Mr Hanford told the Inquiry that there was no resistance to this from a G4S perspective and that it was an “opportunity” for the company.⁴⁸ Mr Saunders confirmed in the June 2014 360-degree contract review that it was estimated that the introduction of an additional 60 beds would increase overall revenue by £1.5 million per year, with a profit margin of £91,000 per year.⁴⁶ This confirmed that G4S’s profits would benefit from the increase in beds.
27. Reverend Nathan Ward, former Head of Tinsley House, told the Inquiry that he raised concerns with Mr Saunders about the increase to three-person cells and its effect on detained people’s welfare, particularly due to the lack of ventilation and privacy in cells. However, Mr Saunders did not consider that these concerns should be shared with the Home Office. Reverend Ward understood that the idea for the increase in beds came from both G4S and the Home Office.⁴⁹
28. In early 2017, the Extra Beds Programme was introduced and an additional 60 beds were installed in Brook House by converting some cells from two-person to three-person cells.⁵⁰
29. These plans were criticised by external sources before and after the changes were implemented, because of the effect that overcrowding would have on detained people’s welfare.

29.1 In the 2016 Shaw report, Mr Shaw said: “Given the pressure on the other facilities, I do not believe this should go ahead.”⁵¹ In the 2018 Shaw follow-up report, he expressed disappointment that the Home Office had rejected this advice and suggested that it was “unacceptable” that cells contained toilets separated only by a curtain.⁵² He commented: “I did not find conditions in those rooms remotely acceptable or decent.”⁵³Mr Shaw recommended again that these practices ceased.⁵⁴

29.2 HM Chief Inspector of Prisons, Mr Peter Clark, warned in his introduction to the 2016 HMIP inspection report that the proposal to bring into use third beds installed in two-person cells “has the potential to adversely affect the conditions in which some detainees are held”. He added that inspectors shared the view of many staff and detained people that it “would lead to a decline in living standards”.⁵⁵ Dr Singh Bhui explained to the Inquiry that a formal recommendation from HMIP was not appropriate because the change had not yet happened:

“As third beds were installed but not yet being utilised, we had no evidence regarding the impact of a third bed on the experiences of detainees. No recommendation was made because inspections do not make recommendations about potential future outcomes, only about evidenced current outcomes.”⁵⁶

29.3 A meeting with Dr Singh Bhui, carried out as part of the external investigations company Verita’s investigation into Brook House, recorded him saying in October 2017 that “having three detainees in a cell is ‘playing with fire’ but means G4S will make more money from the contract”.⁵⁷

30. Concerns about the additional beds were also raised by G4S staff.

30.1 In relation to the impact of three-men cells, Mr Owen Syred, a DCO and Welfare Officer during the relevant period, told the Inquiry:

“what was clear was that, actually, just a cell with two people in it was stuffy, the air was stale, it smelt, there was no access to fresh air, there was no real privacy when they were using the toilet, and, therefore, if – if the system doesn’t work with two people in a room, adding a third person only increases the detrimental impact on living in there. If you’re having to medicate people in order to sleep with two people in the room, then actually adding a third person isn’t going to make it any better. In fact, it will make it demonstrably worse. These are concerns which I actually raised at the time, and I drew the facts of some of the policies which were in existence around minimum sizes that should be given for cell space to Ben Saunders at the time, and suggested that, in fact, we weren’t meeting those with two people, let alone three people.”⁵⁸

30.2 When asked whether there was a noticeable change once the three-men cells were introduced, DCO Daniel Small replied:

“Oh, 100 percent. If you were going to increase the capacity of detained persons at that facility, then surely you would increase the capacity of officers … The environment is horrific in that place.”⁵⁹

31. Mr Hanford told the Inquiry that a joint assessment of risk (by the Home Office, Ministry of Justice and G4S) concluded that the Home Office’s proposal to increase capacity was viable when it was made in 2014.⁶⁰ However, he said that negotiations took a significant amount of time and, by the time the additional beds were added in 2017, the detained population had changed (the percentage of time served foreign national offenders – known as TSFNOs – had increased), the average stay had increased, and there was a significant drug problem concerning a new psychoactive substance known as ‘spice’.⁶¹ However, if the change in the detained population was likely to cause difficulties for the Extra Beds Programme, Mr Hanford did not offer any explanation as to why G4S did not raise concerns in late 2016 or early 2017.
32. By contrast, Mr Julian Williams, Residential Manager, commented in a Senior Management Team (SMT) meeting on 13 April 2017:

“There has been no impact with addition[al] beds. Some detainees [do] not want to share but others are happy to have three detainees in a room.”⁶²

33. G4S and the Home Office eventually agreed in May 2018 that, “having experienced managing the facility with the additional places”, the Extra Beds Programme ought to be discontinued.⁴⁸
34. I agree with Mr Shaw that capacity in the immigration estate should never again be increased by adding extra beds to cells designed for fewer occupants.⁶³ When asked if he considered the introduction of the additional beds to be a mistake, Mr Riley said that he did not know what the “options” were at the time, and it may or may not have been the best option considering that extra capacity was needed.⁶⁴ The adverse impact of accommodating an additional 60 detained people was not given sufficient priority by the Home Office or by G4S, despite the availability of ample information on the risks to detained people’s welfare. Since the Covid-19 pandemic, when statistics have been published, there have been fewer than 200 people detained at Brook House.⁶⁵

The detrimental impact on detained people

35. The physical environment and the conditions at Brook House had a significant detrimental impact on detained people, particularly those with mental ill health or other vulnerabilities.

35.1 D790 gave evidence that Brook House was overcrowded, leading to long queues to use the welfare office and IT equipment.71 He said that the cells were small and cramped.⁶⁶

35.2 D687 described being:

“constantly on edge because of the toxic environment at Brook House and … [the] noise [of officers slamming cell doors shut] was almost painful”.⁶⁷

35.3 D801 described the environment as like a prison, which made it:

“frightening and intimidating. I did not feel safe and I do not think it was safe for someone with my mental health problems.”⁶⁸

36. Tellingly, senior Home Office officials accepted a causative link between the environment at Brook House and the deterioration of detained people’s mental health. The Home Office DES Area Manager for Gatwick IRCs, Mr Ian Castle, told the Inquiry:

“I think, if you spend more than 24 hours in Brook House, you’re going to develop mental health issues. It’s not a nice place to be.”⁶⁹

Not only is this a serious indictment generally of Brook House during the relevant period, but it is also very concerning that a Home Office manager perceived Brook House in this way.

37. Some of those currently working at Brook House also recognised the serious limitations of Brook House and its design. Mr Steven Hewer, current Director of Gatwick IRCs under Serco, recognised that the building and the restrictions that went with it posed challenges for the delivery of a “human[e] regime”.⁷⁰ Efforts must be made to allow more free movement around Brook House, to continue to provide diverting and beneficial activities, and to soften its appearance (as previously recommended by the Brook House IMB, HMIP and Verita).⁷¹
38. Providing a humane regime at Brook House was difficult due to the design of the building. However, these issues and more were exacerbated while the additional beds were in use. I am therefore recommending a limit on the maximum number of detained people sharing each cell at Brook House.

Recommendation 3: Limit on cell sharing The Home Office must ensure that a maximum of two detained people are accommodated in each cell at Brook House.

1. CJS0075153_015 para 42. A number of witnesses to the Inquiry also agreed with this characterisation: Jerry Petherick 21 March 2022 55/4-8; Owen Syred 7 December 2021 57/23-58/2; Dr Hindpal Singh Bhui 24 March 2022 177/18-25, 178/3-16; Gordon Brockington 31 March 2022 90/18-21; SER000455_028-029 paras 81-83; INQ000055_002 para 8; D1851 3 December 202163/20-64/6; Owen Syred 7 December 2021 57/23-58/2; VER000248_018 para 192; John Connolly 2 March 2022 204/1-23; Stephen Webb 8 March 2022, 138/23-25, 139/1-2; SER000453_011;INQ000056_010 para 45; Dr Hindpal Singh Bhui 24 March 2022 154/2-7; Clayton Fraser 28 February 2022 13/20; VER000257_005 para 32; BHM000031_003 para 5b[↩]
2. Philip Riley 4 April 2022 60/12-61/7[↩]
3. DL0000174_006; DL0000167_005[↩]
4. INQ000060_045 para 3.3; Assessment ofGovernmentProgress inImplementing theReport on theWelfare inDetention ofVulnerablePersons: AFollow-upReport to the Home Office by Stephen Shaw, Stephen Shaw, Cm 9661, July 2018[↩]
5. INQ000060_047 para 3.16[↩]
6. INQ000060_046 para 3.13[↩]
7. Assessment ofGovernmentProgress inImplementing theReport on theWelfare inDetention ofVulnerablePersons: AFollow-upReport to the Home Office by Stephen Shaw, Stephen Shaw, Cm 9661, July 2018, para A7.16[↩]
8. VER000223_004-005[↩]
9. KEN000001_011-012 para 56[↩]
10. HMIP000311_014 para S12; see also HMIP000311_015 para S14; HMIP000311_033 para 2.1; HMIP000311_033 para 2.8; HMIP000311_058 para 5.36[↩]
11. CJS000761 018 para s36[↩]
12. Dr Hindpal Singh Bhui 24 March 2022, 177/18-25, 178/3-16[↩]
13. Professor Mary Bosworth 29 March 2022 33/11-16[↩][↩]
14. INQ000052_036 para 143[↩]
15. Philip Riley 4 April 2022 45/12-18, 45/12-46/12, 59/22-60/5[↩]
16. Report on a Full Announced Inspection of Brook House Immigration Removal Centre 15–19 March 2010, HM Chief Inspector of Prisons, June 2010, pp5-7; see also Dr Hindpal Singh Bhui 24 March 2022 176/12-24[↩]
17. Stephen Skitt 17 March 2022 130/16; SER000455_028; VER000266_005; CJS0074048_022 para85; INQ000164_054 para 106; Gordon Brockington 31 March 2022 90/25-91/-5; Jerry Petherick 21 March 2022 55/4-56/20; Peter Neden 22 March 2022 68/3-7[↩]
18. Reverend Nathan Ward 7 December 2021 134/12-136/14; DL0000141_023-024 paras 67-71; Philip Schoenenberger 23 March 2022 12/1-13/6; HOM000916_040; CJS000768_014[↩]
19. CJS000768_014; Dr Hindpal Singh Bhui 24 March 2022 176/23-177/-7[↩]
20. INQ000249_006[↩]
21. INQ000249_005[↩]
22. Report on aFullAnnouncedInspection of Brook House Immigration Removal Centre 15–19 March2010, HM Chief Inspector of Prisons, June 2010, p5[↩]
23. Report on aFullAnnouncedInspection ofBrook House Immigration Removal Centre 15–19 March2010, HM Chief Inspector of Prisons, June 2010, p90; CJS0073709_060; INQ000225_003-004[↩]
24. INQ000064_043 para 9.8[↩]
25. This was the case for most of Brook House’s existence but, as discussed below, there were three beds in 60 cells for a period from 2017 to 2018[↩]
26. Callum Tulley 29 November 2021, 37/6-13, 39/6-17[↩]
27. DL0000143_017-018 paras 63 and 65; DL0000228_044 para 160[↩]
28. DL0000149_008 para 29; DL0000228_044 para 160[↩]
29. INQ000051_029 para 6; INQ000051_030 para 9[↩]
30. CJS000761_018, 049[↩]
31. VER000117_031 para 2.2[↩]
32. Jeremy Petherick 21 March 2022 98/5-7[↩]
33. VER000266_004 para 32[↩]
34. VER000266_004-005 paras 34 and 38[↩]
35. Jeremy Petherick 21 March 2022 99/25-100/7[↩]
36. See, for example, DPG000021_011-012 para 36[↩]
37. Planning Register, Crawley Borough Council, Officer Report, para 23[↩]
38. HOM0332165_052 para 170[↩]
39. VER000116_001 ref 5.2[↩]
40. VER000116_001 ref 5.2 [↩]
41. VER000116_001 ref 5.2[↩]
42. HOM0332005_018-019 para 56[↩]
43. Report on an Unannounced Inspection of Brook House Immigration Removal Centre 30 May–16 June2022 (HMIP000702), HM Chief Inspector of Prisons, September 2022, p5 para 2; see also pp3 and 64 and paras 1.11, 1.17, 2.27, 2.34, 3.5 and 3.7-3.8[↩]
44. CJS0074047_009 paras 41-46; CJS000768_027, 044[↩]
45. CJS0074047_009 para 45[↩]
46. CJS000768_027[↩][↩]
47. Jeremy Petherick 21 March 2022 41/4-42/15; CJS0074047_009 para 43[↩]
48. CJS0074048_021 para 79[↩][↩]
49. Reverend Nathan Ward 7 December 2021 146/10-148/21[↩]
50. CJS0074048_020 para 74[↩]
51. INQ000060_045 para 3.5[↩]
52. Assessment of Government Progress in Implementing the Report on the Welfare in Detention of Vulnerable Persons: A Follow-up Report to the Home Office by Stephen Shaw, Stephen Shaw, Cm 9661, July 2018, paras 2.75 and 2.77[↩]
53. Assessment of Government Progress in Implementing the Report on the Welfare in Detention of Vulnerable Persons: A Follow-up Report to the Home Office by Stephen Shaw, Stephen Shaw, Cm 9661, July 2018, p32[↩]
54. Assessment of Government Progress in Implementing the Report on the Welfare in Detention ofVulnerable Persons: A Follow-up Report to the Home Office by Stephen Shaw, Stephen Shaw, Cm 9661, July 2018, recommendations 7 and 8[↩]
55. CJS000761_005[↩]
56. HMIP000697 006 para 18[↩]
57. VER000193_001[↩]
58. Owen Syred 7 December 2021 147/21-25, 148/1-12[↩]
59. Daniel Small 28 February 2022, 114/8-12, 115/21, 147/19-23[↩]
60. Lee Hanford 15 March 2022 99/18-100/6[↩]
61. Lee Hanford 15 March 2022 94/19-100/24[↩]
62. CJS000582_002[↩]
63. CJS0074048_021 para 79 [↩]
64. Philip Riley 4 April 2022 70/3-7[↩]
65. Immigration System Statistics, year ending March 2023 (Detention – Summary Tables), Home Office, May 2023, table 3a. The latest statistics show the number of people at Brook House on 31 March 2023[↩]
66. D790 21 February 2022 49/12[↩]
67. DPG000021_025 para 78[↩]
68. BHM000034_028 para 84[↩]
69. Ian Castle 15 March 2022 38/16-18[↩]
70. Steven Hewer 1 April 2022 87/3-7[↩]
71. HMIP000613_020 para S36; HMIP000613_028 para 1.59; HMIP000613_045 para 3.16; IMB000156_005; CJS0073709_039-40 paras R17 and R23[↩]