Publication — not a case

The inquiry that found an inherently dangerous restraint technique

A public inquiry into an immigration removal centre found force used inappropriately against ten detainees, an "inherently dangerous" technique used on four, and footage that had been there all along.

Immigration · 2020s

What this is

A public inquiry under the Inquiries Act 2005, chaired by Kate Eves, into the mistreatment of people detained at Brook House, an immigration removal centre at Gatwick, between 1 April and 31 August 2017. It was set up in November 2019, after a BBC Panorama programme filmed covertly at the centre.

The inquiry reported in three volumes on 19 September 2023 as HC 1789-I to III, making 33 recommendations across ten areas of concern. It examined the use of force by staff and contractors in cells, reception, the segregation unit and escort, and took evidence on the restraint of people who were naked or near-naked, on floor restraint, handcuffs, waist restraint belts, and on the segregation of vulnerable people.

What it records

Force was used inappropriately against ten detainees, who are identified in the report by cipher only. An “inherently dangerous restraint technique” was used on four of them. Pain was unnecessarily inflicted on four. Pressure applied to one detainee’s neck during restraint “must have been terrifying and could have resulted in serious injury”.

Three detainees were inappropriately segregated in a separate part of the centre. Staff made humiliating comments to detainees who were attempting to take their own lives.

Kate Eves wrote that her report was the latest in a long line of investigations into immigration detention, “many, with depressing regularity, making broadly similar findings and recommendations”.

How to read it

This is a finding about a system and about ten identified people. It is not a finding about any individual member of staff, and it is not a finding of criminal liability: an inquiry under the Inquiries Act 2005 establishes facts and makes recommendations, and decides no charge against anyone.

The specific counts are what make it usable in teaching. Ten, four, four, one: those are conclusions reached on evidence about named events, from a body that watched the footage. That is a different order of claim from an allegation, and a different order again from a statistic. Where a service wants to argue that its restraint is not the kind an inquiry would criticise, this is the document that describes the kind.

The phrase “inherently dangerous restraint technique” is the inquiry’s own, and it is applied to a technique rather than to the person who used it.

Where it stops

Five months in one centre, on footage that covered part of that period and was reviewed after the event. It tells you about England’s immigration detention estate only as far as this centre.

The government responded on 19 March 2024 in HC 1041, reporting progress against the ten areas of concern. This page does not assess implementation, and no reader should assume the recommendations were delivered because a response exists.

The technique the inquiry called inherently dangerous is described in the report. This page does not describe it, because describing a restraint method is not the same as warning against it.

Sources

Where staff are working with people in crisis whose behaviour is volatile, our vulnerable and volatile persons training covers the assessment that has to come before any hands-on response.

Reviewed 20 October 2026.

All immigration cases  ·  Restraint Casebook

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