HGF -v- Secretary of State for the Home Department (anonymity order)

Administrative CourtHigh CourtKing's Bench DivisionAnonymity OrderOrder

Claim number: AC-2026-LON-000816

IN THE HIGH COURT OF JUSTICE
KING’S BENCH DIVISION
ADMINISTRATIVE COURT

23 February 2026

Before:

Mr Justice Jay

Between:

HGF

-v-

SECRETARY OF STATE FOR THE HOME DEPARTMENT

Order

UPON the Claimant’s application for interim relief

AND UPON considering the papers filed by the Claimant

  1. Pursuant to CPR r. 39.2, the Claimant be granted anonymity and must be referred to in these proceedings only as HGF. Nothing may be published which may lead to his identification.
  2. Application for interim relief refused.

Reasons

Ground 1
There is nothing to indicate that the Defendant applied the wrong legal test. The issue was whether there were reasonable grounds to believe that the Claimant was the victim of modern slavery. In my view, there were considerable discrepancies in the accounts the Claimant gave which cannot be explained away by his “being confused” or by difficulties in interpretation from Amharic to English. Overall, the Defendant was entitled to conclude that the Claimant had not given a credible account, and that the relatively low threshold had not been met.

Ground 2
I do not read the Defendant’s guidance as requiring her to provide a provisional decision identifying the key inconsistencies and then inviting further representations. The guidance requires the Defendant to provide a further opportunity for additional evidence to be supplied in the event that the Defendant believes that the account given may have been incomplete. That opportunity was afforded on 19 February. What the Claimant seeks is, in effect, the “minded to refuse” procedure which the Court of Appeal in R v SSHD, ex p Thirakumar [1989] Imm AR 402 specified in pre 1993 Act asylum cases concordant with the highest standards of procedural fairness. Those standards do not apply to modern slavery decisions.

General
The Claimant’s bundle is far too large. The Claimant’s SFG bear the hallmarks of being word-processed and generic. In future, please do not lecture the Court on well established principles, provide the Court with more focused grounds, and think about the size of the bundle.