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A high court judge ruled that the British home secretary’s decision to reduce protections for potential trafficking victims to allow the "one in, one out" asylum returns deal to proceed was unlawful.
Source: High Court Judgment
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The legal challenge was brought by five small boat asylum seekers earmarked for return to France, four from Eritrea and one from Sudan.
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The challenge related to a change in guidance on the "one in, one out" scheme which meant that those denied trafficking protections no longer had the right to ask for it to be reconsidered.
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Mr Justice Sheldon published a judgment on Friday morning finding that Shabana Mahmood’s decision on the guidance was unlawful.
Source: High Court Judgment
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The judge found that other elements relating to individual decisions taken by the home secretary regarding the five cases were lawful.
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The judge found that the decision to amend the trafficking guidance to prevent reconsideration of cases given an initial negative decision made a "real difference" in two of the asylum seekers’ cases.
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The judge found that the decision to amend the trafficking guidance did not make a difference in two of the other asylum seekers’ cases.
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All five asylum seekers were given permission by the judge to proceed with their legal claims.
Relevance: supporting · Type: background
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The "one in, one out" deal involves one person who has travelled from France to the UK on a small boat being forcibly returned to France in exchange for another asylum seeker in France who has not attempted to cross the Channel.
Relevance: primary · Type: action
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Shabana Mahmood amended the trafficking reconsideration guidance in order to expedite returns of some small boat arrivals to France.
Relevance: supporting · Type: background
Confidence80%
It is likely that more than 1,000 people have been removed to France under the scheme since it started last August.
Relevance: supporting · Type: background
Confidence80%
Many people removed to France under the scheme have subsequently disappeared.
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Hundreds of small boat arrivals are in UK detention centres awaiting forced return to France.
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The home secretary argued that because France is a signatory to treaties protecting trafficking victims, their cases could be dealt with in France.
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The court heard evidence that victims of trafficking who are not French or were not trafficked in France do not get the same protections in France.
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In the UK all trafficking victims have a right to the same protections.
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Government disclosures during the case stated that officials were aware there could have been problems with accommodating some of the asylum seekers sent back to France due to shortages of places for them to live.
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Officials were aware before UK prime minister Keir Starmer and French president Emmanuel Macron agreed the "one in, one out" deal on 10 July 2025 that the French government did not afford equal protection to asylum seekers returned from the UK who may have been trafficked in countries such as Libya compared with that given to French trafficking victims or to those who were trafficked inside France.
Sheldon, Mr Justice
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Mr Justice Sheldon said: "In my judgment such a decision-making process cannot be regarded as robust and effective."
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Three of the five asylum seekers who challenged the policy were removed to France by the Home Office.
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Lawyers are calling on the home secretary to bring the three removed asylum seekers back to the UK.
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Elizabeth Cole is a solicitor at Duncan Lewis representing two of the five asylum seekers in the case.
Elizabeth Cole, solicitor
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Elizabeth Cole said: "This has had significant consequences: large numbers of vulnerable people have been unlawfully removed to France as a result."
Elizabeth Cole, solicitor
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Elizabeth Cole said: "We now urge the home secretary to acknowledge her obligations under both the treaty and domestic law, and bring our client, as well as potentially many others who have been unlawfully removed, back to the UK."
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An asylum seeker represented by Elizabeth Cole said: "It is really a feeling of hopelessness that I have."
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An asylum seeker represented by Elizabeth Cole said: "I believe that the Home Office had all the evidence in my case, but chose not to consider this."
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An asylum seeker represented by Elizabeth Cole said: "In their doing so, they failed to consider my case properly."
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An asylum seeker represented by Elizabeth Cole said: "I truly believe if they had properly considered my evidence, I would not have been returned to France."
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Zubier Yazdani is of Deighton Pierce Glynn and represented one of the other asylum seekers.
Zubier Yazdani, representative
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Zubier Yazdani said: "We are pleased that the court has rightly recognised that reconsideration is a fundamental safeguard."
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Emma Ginn is the director of the charity Medical Justice.
Emma Ginn, director
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Emma Ginn said: "This is symptomatic of the government’s reprehensible attitude to trafficking survivors."
Emma Ginn, director
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Emma Ginn said: "Our clients’ medical evidence is disregarded and their trafficking disclosures are treated as an inconvenient impediment to removal."
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