Decisions of the parole board whether to recall a prisoner released on licence did not amount to the determination of a criminal charge. Therefore the prisoner had no right to an oral hearing under Art.6 European Convention on Human Rights.

[2002] EWCA Civ 1641

A recall to prison after release on licence from a determinative sentence was an administrative act. It amounted neither to the bringing of a criminal charge nor the determination of civil rights or obligations. Therefore, neither Art.5 nor Art.6 European Convention on Human Rights were engaged.

[2002] EWHC 769 (Admin)