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Mental Health newsletter

Mental Health - September

Disclosure in mental health tribunal proceedings

In its first mental health decision, the new appeals tribunal has given important guidance

Wherever possible, hospitals, patients and their solicitors should try to agree on what documents are to be disclosed in mental health proceedings. That is the view of a new appeals tribunal in its first ever mental health decision.

The new, ‘second-tier’ tribunal will hear a wide variety of health, education and social care appeals. In Dorset Healthcare NHS Foundation Trust v MH [2009] UKUT 4 (AAC) a detained mental health patient wanted access to his medical records. The ‘first-tier’ tribunal gave him that access but the hospital in which the patient was detained challenged the decision.

The appeals tribunal criticised many of those involved in the case: the hospital, for making the challenge in the first place; the patient’s solicitors, for involving the tribunal prematurely; and the tribunal itself, for making its decisions too timidly. But the appeals tribunal also gave valuable guidance on how disclosure disputes should be resolved in the course of mental health proceedings:

  • All parties should be flexible, seek to avoid formality and do all they can to avoid applying to the tribunal.
  • Where a direction is required, the tribunal has broad powers.
  • The starting point is full disclosure, and the burden will be on the hospital to show why it should not be given.
  • If there is confidential information concerning a third-party, he or she should be invited to consent to its disclosure.
  • Even without consent, it might still be possible for a hospital to disclose third-party information to a patient’s solicitors, subject to their undertaking not to disclose that information to their client.
  • If agreement still cannot be reached, the parties should commit their respective arguments to writing.
  • Ultimately, it might be necessary for the party seeking an order to apply to the tribunal. If so, all parties should identify issues on which they have been able to agree.
  • Ordinarily, it is the first-tier tribunal that will consider such an application.
  • The tribunal might wish to obtain the third-party’s views on disclosure. If so, those views should be solicited by the hospital. A third-party should not have any direct involvement in the tribunals’ procedures.

There is something else this case reveals: the tribunal has far stronger disclosure powers now than ever before. Under the rules that used to apply, the tribunal could itself disclose documents, but only if it had already received them. And it couldn’t compel one party to give disclosure to another. Under its shiny new rules, however, a tribunal can direct anyone to disclose documents to anyone else, even if it has not received those documents and regardless of whether it even wishes to see them. This power might not be widely understood.

David Hewitt, Partner
Weightmans LLP
david.hewitt@weightmans.com