EWCA Civ 1224
In general there was no requirement to explain to a prisoner why a squat search was required. Additional days imposed on a serving prisoner after disciplinary proceedings did not have the effect of adding to a prisoner's sentence and were not a fresh sentence of imprisonment. Whilst the domestic courts had regarded proceedings before a prison governor as disciplinary proceedings as opposed to criminal proceedings, fairness in the proceedings was still required.
CA (Civ Div) (Lord Woolf of Barnes LCJ, Tuckey LJ, Arden LJ)