19th December 2022
Today the High Court handed down its judgment in respect of the many legal claims brought against the Rwanda removal policy.
On the face of it, the government of the United Kingdom appear to have won – and that is certainly how the judgment has been reported:
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But.
In two ways the government has not won, and indeed this may not be a welcome judgment for the government.
Let me explain.
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The wide legal challenge was to the policy.
In effect the policy is as follows: the Home Secretary can decide that asylum claims made in the United Kingdom should not be determined here, and that instead the persons who have made those claims should be removed to Rwanda to have their asylum claims determined there.
A legal challenge to any policy is always difficult – almost impossible.
This is partly because courts do not like intervening in matters of policy, as opposed to reviewing particular rules and individual decisions.
It is also partly because to say that a policy is unlawful means, in effect, that every possible rule made under that policy and every possible decision made under that policy will be unlawful.
And it is partly because policies can be adapted and modified so that the possibility of the policy itself always being unlawful can be avoided.
A policy is always the hardest target to hit in the administrative law courts.
It was therefore no great surprise that the High Court in this case – with a bench comprised of the two most experiences judges in administrative law matters – rejected the challenge to the policy as a whole.
And so, the government “won”.
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The government, however, also lost.
In the eight individual cases under review, the High Court decided that the removal decisions be quashed and the Home Secretary take the decisions again with proper regard to individual circumstances.
Look at the final paragraph carefully:
That paragraph indicates that the government lost on nineteen particular decisions in this case.
Nineteen.
Each of those nineteen decisions was legally flawed: every single one.
The policy may well be lawful – but in not one case was the policy lawfully applied.
And so the the government lost all the individual cases.
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Now we come to the real defeat for the government.
The import of the High Court decision is that in respect of each removal to Rwanda under the policy, the Home Office has to apply the policy in a robust and reasoned manner to the individual circumstances of each case in each of the decisions to be made.
Otherwise the removal will be successfully appealed or reviewed.
But for page after page of this judgment there is a catalogue of Home Office errors in respect of each of the cases.
The impression one forms reading the judgment as a whole is that, with the resources and administrative competence available, the Home Office simply is not capable of making all the individual decisions so that many removals to Rwanda are likely.
For the legal issue with decisions which need to be made on individual circumstances is that each decision can be appealed or otherwise legally challenged according to those circumstances.
Or to put it another way: the government has legally saved its Rwandan removal policy at the expense of making the lawful implementation of that policy extraordinarily resource-intensive and financially expensive.
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Of course, this judgment may be appealed by the claimants – though it seems at first read a strong judgment by two highly regarded judges in this field, and I do not think an appeal would be likely to succeed.
And so perhaps the policy under challenge may actually be implemented – though it seems there are no current plans to send any asylum seekers to Rwanda.
But.
Even if this policy is one day lawfully implemented – if – it will be always be an administrative and financial drain of the highest order on the Home Office and thereby the taxpayer.
Many will say that the policy is immoral and should be dropped on that basis alone.
Being immoral, however, does not make a policy unlawful.
But a policy being lawful also does not make it practicable.
The government and its supporters may raise a cheer that the policy is itself has been held to be not unlawful.
But today’s judgment means that – like the chartered flights to Rwanda last summer – the lawful implementation of the policy may never really get off the ground.
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