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R (Hirst) v Parole Board and Home Secretary | 
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| Issue:  | 
Burden of proof in Discretionary Lifer Panels; whether a failure by the Parole Board to agree in advance of a hearing that the burden of proof was not on the prisoner allowed him to commence proceedings seeking a remedy under the Human Rights Act 1998. | 
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| Court:  | 
Administrative Court | 
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| Reference:    | 
CO/3938/2001 | 
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| Neutral Citation:    | 
[2002] EWHC 1592 (Admin) | 
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| Judge(s):  | 
Moses J | 
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| Date:  | 
31 May 2002 |