Hutchinson Reid v UK 50272/99 [2003] ECHR 94
Treatability test not necessary for Article 5(1) compliance (re Scottish removal of this test); breaches of Article 5(4) due to onus being on patient and the delay for the case to come to the House of Lords.
Update
A change made by the Mental Health Act 2007 is related to this case. See Appropriate treatment test replaces treatability test and applies to all patients under long-term detention 3/11/08
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