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R (PD) v West Midlands and North Mental Health Review Tribunal | 
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| Issue:  | 
Whether there was a risk of perceived bias or a breach of Art 6 European Convention where the Tribunal medical member was employed by the detaining authority at a different hospital. | 
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| Court:  | 
Administrative Court | 
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| Reference:    | 
CO/139/2003 | 
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| Neutral Citation:    | 
[2003] EWHC 2469 (Admin) | 
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| Judge(s):  | 
Silber J | 
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| Date:  | 
24 October 2003 |