R (Hempstock) v MHRT  EWHC Admin 664
Tribunal have same powers when reconvening after unfulfilled recommendations as at original hearing.
Tribunal made recommendations then reconvened as they were not followed. They considered that they had no power except to discuss the failure to follow the recommendation.
Their power was not so restricted. Decision quashed. Remitted to same Tribunal.
39 BMLR 123?
Possible Bailii link (not there when checked last night, but might have appeared since)
The judgment in this case is available but has not yet been uploaded to MHLO. Contact me if you need to read it.