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R (Kai Salter) v (1) Secretary of State for Justice and (2) Parole Board | 
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| Issue:  | 
Whether holding the oral hearing of an application for release by an indeterminate sentence prisoner 3 months after tariff expiry breached Art 5(4) ECHR; whether the Board applied the wrong test in law or did not have adequate evidence to uphold detention; whether a failure to recommend a transfer to open conditions was irrational; whether an 18 month gap until the next review breached Art 5(4). | 
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| Court:  | 
Administrative Court | 
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| Reference:    | 
CO/11263/2008 | 
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| Neutral Citation:    | 
[2009] EWHC 1497 (Admin) | 
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| Judge(s):  | 
Higginbottom J | 
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| Date:  | 
26 June 2009 |