“…In Re SS (Secure Accommodation Order) [2014] EWHC 4436 (Fam), Hayden J, however, cited this passage from Charles J’s judgment in the Knowsley case with this comment:…”
“…In Re SS (Secure Accommodation Order) [2014] EWHC 4436 (Fam), Hayden J applied the concept of proportionality when refusing an application for a secure accommodation order. There is also some authority from this court th…”
“…tion Order: Right to Liberty) [2001] 1 FLR 526, Section 25 was found to be compatible with Article 5 ECHR. More recently, in Re SS (Secure Accommodation Order) [2014] EWHC 4436 (Fam)at [26], Hayden J declined to make a secure accommodation order on proportionality grounds, and in Re W (2016, above) at [24] this court accepted as “plainly ri…”