Special Category. Ruán O’Donnell

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by the British authorities in relation to Irish prisoners in England. The breakthrough signalled that the Commission in Strasbourg believed there was a prima facie breach of Article Six arising from the refusal of the Home Office to permit Campbell to consult with his lawyers between October 1976 and March 1977. This essentially reasserted the Golder v UK (1975: 1 ECHR, 524) judgement of February 1975. Another element of the complaint focused on the conduct of the Board of Visitors who had punished the Tyrone man with solitary confinement and loss of remission. However, this potentially significant advance was tempered by the failure of the Commission to accept claims from Campbell and others that Article Three had been breached by the violence inflicted by staff on the Albany prisoners.147 The case was still under consideration in March 1982 when Campbell was released and deported, having served all but a few months of his full sentence.148 Prisoners could petition the Home Secretary for restoration of forfeited remission under Prison Rule 56 (2), but IRA members rarely pursued this theoretical option. Campbell evidently did not elicit the support of the various adjudicating bodies who had imposed sanctions and who enjoyed in doing so the capacity to make restoration under Order 42 (a) of Prison Standing Orders (1977). This directed: ‘Where a prisoner’s institutional behaviour has shown a significant improvement, indicative of a genuine change of attitude (as opposed to staying out of trouble), and the improvement is likely to be maintained, a governor or Board of Visitors, depending upon which adjudicating authority originally awarded the forfeiture of remission, may restore part of the remission a prisoner is forfeited if restoration will bring forward the earliest date of release’.149

      Re-organization and resistance, February-July 1978

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