Tuesday, 23 October 2012

Law report - constitutional claim against Prisons Commissioner

Nisbett v Commissioner of Prisons [2012] SC( Bda) 57 Civ

The Applicant had brought a constitutional motion to complain about his treatment whilst in prison for seven years.

The acts complained of were:
  1. being beaten by prison officers or fellow prisoners on their instigation;
  2. subject to inhuman solitary confinement;
  3. being given unjustifiable restrictions on family visits;
  4. being given unjustifiable restrictions on his religious diet requirements;
  5. parole documents being destroyed by corrections officers;
  6. loss of earnings due to release on licence being delayed by two years;
  7. exposure to second-hand cigarette, cannabis and crack cocaine smoke from other cells

The respondent sought to strike out the claim because one should not bring a constutional motion if there are other means of legal redress.

Hellman J held that for (1), above, the applicant could have brough a civil claim for assault or battery [33]. However, the allegation of the abuse of state power meant that this might not be adequate redress in the circumstances [34]. He did not strike out the claim but invited the parties to make submissions on what should happen with that claim next [40].

Similarly for (5) above, which might constitute wrongful imprisonment, the consitutional claim would be allowed to proceed [41].

The remaining issues were more suitable for judicial review proceedings regarding whether the prison rules had been correctly applied [45]. These allegations were struck out for the constitutional motion [48]. Presumably the applicant could re-apply for leave to commence judicial review proceedings.

No comments:

Post a Comment