Consultation responses

UKVI’s Front End Services

The team covered various issues including the lack of clarity around the functions of UKVI and its subcontractors, technical issues with the application process, the IDV app, online forms, and issues with submitting evidence.

We also noted issues with free appointments and Visa Application Centres.

Please find our response here.

ILPA’s response to the Independent Chief Inspector of Borders and Immigration (ICIBI)’s Second Annual Inspection of ‘Adults at Risk’ in immigration detention

We kept our response focussed on concerns around stakeholder engagement in policy making within Immigration Enforcement in the Home Office.

For example, the Home Office designed the ‘Enhanced Screening Tool’ in response to the ICIBI’s first Annual inspection of Adults at Risk. The Home Office sent their recommendations to a limited group of NGOs on 4 February 2020; the deadline for responses was 13 February 2020. ILPA and nine other NGOs wrote to the Home Office on 12 February 2020, expressing concern over the short deadline and the limited scope of the feedback sought. It was confirmed on 6 March 2020 that a full consultation would not take place.

We cover further instances of inadequate engagement with the proposed introduction of standards for medical evidence, changes to policy on the detention of victims of trafficking and Prison Parity.

Our full response can be found here.

Independent Review of Administrative Law (IRAL)

ILPA’s response to IRAL highlighted that “[T]he starting point for the review must be a reminder that judicial review is about enforcing the law as enacted by Parliament, and can only be successful where the Government has acted unlawfully. To allow the Government to act in an unlawful manner, unchecked by the law, would undermine the sovereignty of Parliament.”

The number of judicial reviews have dropped steadily since 2015/2016 and we suggested that research should be undertaken into what proportion of current immigration judicial reviews are challenging decisions that could previously be appealed.

We showed the importance of judicial review by referring to trafficking cases and through the use of case studies.

Please find the full response here.

ILPA’s response to the Justice Committee’s future of legal aid inquiry

The response discusses the impact of the Legal Aid, Sentencing and Punishment of Offenders Act 2012 (LASPO) on access to justice, the role of the Legal Aid Agency and challenges for the provision of legal aid over the next decade.

The full consultation response can be found here.

We are very grateful to each and every member who responded to the respective calls for evidence.