High Court rules factual errors fatally undermined parole refusal decision
The High Court has quashed a decision by the Parole Board for England and Wales to refuse the release of Ryan Halliday, after finding the panel relied on material mistakes of fact.
In Ryan Halliday, R (on the application of) v The Parole Board for England and Wales [2026] EWHC 340 (Admin), His Honour Judge Charman, sitting as a High Court Judge, ruled that both the original decision and a subsequent reconsideration were legally flawed.
Mr Halliday is serving a discretionary life sentence imposed on 30 November 2017 for three offences of possession of a firearm and ammunition with intent to endanger life. His minimum term of eight years and six months expired on 10 March 2025.
Following an oral hearing on 28 July 2025, the Parole Board declined to direct his release or recommend transfer to open conditions. A reconsideration decision dated 17 September 2025 upheld that refusal.
Mr Halliday challenged both decisions by way of judicial review. Permission was granted in December 2025.
The court identified two clear factual errors in the Parole Board’s reasoning. First, the panel proceeded on the basis that Mr Halliday had committed serious offences while on licence. The judge found this to be incorrect: he had never committed offences while on licence.
Second, the panel referred to concerning custodial behaviour, including an adjudication for obstructing a prison officer and intelligence suggesting involvement in drug distribution. However, Mr Halliday’s appeal against the adjudication had been allowed. The decision itself also recorded that there was no supporting police intelligence and that no weight was placed on the allegations.
Judge Charman concluded that both errors were objectively verifiable and not attributable to Mr Halliday or his advisers. Crucially, the panel had expressly stated that it placed “particular weight” on these matters. The judge held that this demonstrated the mistakes played a material part in the decision-making process.
Applying the principles set out in the Criminal Justice Act 2003 section 237A, the court found the panel had taken into account risks that did not exist when determining that Mr Halliday continued to pose more than a minimal risk of serious harm if released.
The reconsideration decision was also quashed. The judge held that it was unreasonable to conclude the factual errors were not material, given the panel’s own reasoning.
The court ordered that the parole review be remitted to the Parole Board for a fresh oral hearing to be conducted within its existing framework. No order for costs was made, as the Parole Board adopted a neutral stance in the proceedings.