9 Response Under Consideration AI-assessed

Ensure effective operation and auditing of all Rule 35 limbs

Recommendation

The Home Office must, across the immigration detention estate, assure itself that all three limbs of Rule 35 of the Detention Centre Rules 2001 (reports by a medical practitioner where: (i) it is likely that a detained person's health would be injuriously affected by continued detention (Rule 35(1)); (ii) it is suspected that a detained person has suicidal intentions (Rule 35(2)); or (iii) there is a concern that a detained person may have been a victim of torture (Rule 35(3))) are being followed, are operating effectively and are adequately resourced, in recognition of the key safeguarding role that the Rule plays. The Home Office must also regularly audit the use of Rule 35 in order to identify trends, any training needs and required improvements.

Published Evidence Summary
The following publicly available evidence relates to this recommendation:
The Home Office stated in March 2024 that this recommendation was "Under Consideration," noting the existing detention gatekeeper system and Adults at Risk policy, and an ongoing review of the AaR policy and Rules 34 and 35 (Official government response, March 2024). A Written Parliamentary Question in January 2025 indicated the work was "on track for closure by summer 2025" (Written PQ 23170, January 2025). However, a High Court ruling in December 2025 found the Home Secretary failed to comply with Article 3 ECHR systems duty in Rule 35 safeguarding at Brook House between July 2023 and March 2024, with only a small number of Rule 35 reports filed despite numerous care plans (AH and IS v SSHD [2025] EWHC 3269 (Admin)). Furthermore, an HM Inspectorate of Prisons review in August 2025 (published September 2025) reported that Rule 35 appointments were taking up to three weeks and there was a routine failure to submit reports for suicidal detainees, indicating a lack of effective operation and auditing.
How was this assessed?
Assessed by gemini-2.5-flash on 18 Mar 2026
Checked data held on this site (government responses, progress updates, independent evidence)
External sources searched: www.gov.uk, www.legislation.gov.uk, hansard.parliament.uk
This recommendation requires implementation across many organisations. The assessment reflects central policy response, not adoption in individual organisations.
Jurisdiction
England
Response
Under Consideration
Under Consideration Home Office
19 Mar 2024

The detention gatekeeper system reviews suitability for detention. The Adults at Risk in immigration detention policy is in place. A review of the AaR policy and Rules 34 and 35 is underway.

Read Full Response
Progress Timeline
court_ruling
15 Dec 2025

High Court ruling AH and IS v SSHD [2025] EWHC 3269 (Admin) (15 December 2025): Home Secretary failed to comply with Article 3 ECHR systems duty in Rule 35 safeguarding at Brook House between July 2023 and March 2024. Only 17 Rule 35(1) and 3 Rule 35(2) reports filed despite 260 ACDT care plans during this period.

Parliamentary Answer
14 Jan 2025

Angela Eagle, Written PQ 23170 (15 January 2025): 'On track for closure by summer 2025.'

Published Evidence

Published assessments of implementation progress from inspectorates, select committees, official progress reports, and other sources. Check the source type badge to see whether each assessment is independent or government self-reported.

Insufficient Progress
03 Sep 2025
HM Inspectorate of Prisons Inspection Report

Rule 35 appointments taking up to 3 weeks - far too long. Routine failure to submit reports for suicidal detainees. Home Office identification of vulnerabilities inadequate.

View detailed findings

Based on Independent Review of Progress visit in August 2025, following up 13 concerns from August 2024 inspection. Brook House run by Serco held 192 detainees at time of visit.

Report on an independent review of progress at Br… View Source
Insufficient Progress
19 Sep 2024
Brook House Inquiry Chair Other

Inquiry Chair Kate Eves described government response as "inadequate" and called for a "reset" with the new government. Warned abuse "becomes a question of when, not if" it happens again.

View detailed findings

In September 2024, Kate Eves told Channel 4 News she was "disappointed with what I see as an inadequate response by the former government to an important report." She noted the inquiry cost about £20 million over four years. Home Office lawyers had argued her "recommendations are not binding."

Channel 4 News interview, September 2024
Source
Report The Brook House Inquiry Report 19 Sep 2023
Responsible Bodies
Home Office Primary
Recommendation age 2.5 yrs
Last formal update 15 Dec 2025