In the investigation by school governors of allegations against a pupil, there was a duty to disclose the case against the pupil. Parliament had made it clear that a pupil, through its parent, had a right to be heard, and such a right would be worthless unless the parent knew the case against the child. There was no requirement for a school to apply any of the detailed provisions or underlying principles of the Police and Criminal Evidence Act 1984. The 1984 Act and the Codes of Practice could not serve as more than a touchstone outside the criminal justice process, but could help in deciding what amounted to improper pressure.

CA (Civ Div) (Morritt LJ, Brooke LJ, Sedley LJ)

21/12/1999