The King (on the application of GNH) -v- SSHD (anonymity order)

Administrative CourtHigh CourtAnonymity OrderOrder

Claimant No: AC-2026-LON-000571

In the High Court of Justice
King’s Bench Division
Administrative Court

16 February 2026

Before:
Mrs Justice Jefford DBE

Between:
The King (on the application of GNH)
-v-
SSHD

UPON the Claimant filing this judicial review claim to challenge the public order disqualification decision made by the Defendant on 7th November 2025

AND UPON considering the Claimant’s application dated 6 February 2026 for interim relief to be considered within 7 days

IT IS HEREBY ORDERED THAT:

  1. The Claimant is granted interim relief in the form of a mandatory order for the Defendant to reinstate the recovery period and for a Modern Slavery Needs Assessment to be conducted to identify the Claimant’s recovery needs arising from his experience of modern slavery and to assess any support he may require under the Modern Slavery Victim Care Contract (“MSVCC”), in keeping with the Modern Slavery Statutory Guidance and the Guidance on Adults at risk: detention of potential or confirmed victims of modern slavery (accessible version),
    version 4.0 updated on 22 January 2026.
  2. The Defendant has liberty to apply to vary or discharge this order on 48 hours’ notice to the Claimant’s legal representatives.
  3. Costs reserved.

Reasons

  1. The application is made in reliance on the judgment in R (on the application of ABW) v Secretary of State for the Home Department [2025] EWHC 3280 (Admin). The claimant submits that Mr Justice Morris allowed that claim on grounds that correspond to ground 1 of the present claim and that there is, therefore, a strong prima facie case that the public

Form JR-MPA. Judicial Review. Miscellaneous Paper Application. Version September 2020

order disqualification in the present case was unlawful.

I have had regard to the decision of Mould J in R (on the application of EPS) v SSHD including whether it is appropriate to make a mandatory order against a public body and whether, as in that case, it would be more
appropriate to direct an oral hearing before deciding whether to do so. I am satisfied, following the reasoning of the Mould J in EPS and taking account of the claimant’s imminent release from custody that I should grant the interim relief sought on the papers, but that the defendant, who has made no submissions on the application, should have liberty to apply to vary or discharge the order on short notice.

It appears that there are at the least significant similarities between ABW and the present case. The decision in the present case does not place reliance on the “high bar” referred to in the statutory guidance but the
decision in AWB more broadly finds the statutory guidance to have unlawfully fettered the defendant’s discretion.

UPON consideration of the Claimant’s N461 and Statement of Facts and
Grounds

AND UPON considering the Claimant’s application for anonymity pursuant to
39.2(4) of the Civil Procedure Rules

IT IS ORDERED THAT:

  1. The Claimant’s application for anonymity is granted pursuant to CPR 39.2(4), with effect from the date of this order and until further order.
  2. There shall be substituted for all purposes of this claim in place of references to the name of the Claimant the letters GNH.
  3. Costs reserved.