ABSTRACT
R v Board of Visitors of Hull Prison ex p St Germain (No 1) (1979) CA: Prisoners may argue breach of principles of natural justice in disciplinary proceedings
Facts As a result of their part in riots at Hull Prison, the applicants were subjected to various disciplinary penalties by the Board of Visitors. They sought orders of certiorari to quash the disciplinary awards, on the grounds that the Board had failed to observe the principles of natural justice. Their applications were refused by the Divisional Court, on the preliminary ground that the determinations of the Board of Visitors in these circumstances could not be subject to judicial review, but concerned merely internal and domestic disciplinary matters. Further, recognition of the right of prisoners to apply for judicial review of decisions relating to prison discipline would render the position of the prison authorities intolerable. The applicants appealed to the Court of Appeal.
