A life prisoner did not have the right to be tried by an independent adjudicator rather than by a prison governor for offences contrary to the Prison Rules 1999 where in the circumstances there were no consequences sufficiently serious to trigger the third of the criteria in Engel v The Netherlands (1979-80) 1 EHRR 647, and the European Convention on Human Rights 1950 Art.6 was not engaged.

[2005] EWCA Civ 1009