Thursday, 18 April 2019

Unlocking Children

There are two strong reports out today arguing for radical change to the use and practice of custody for children in England and Wales. The End Child Imprisonment Campaign (ECI) has called for the immediate closure of Young Offender Institutions and Secure Training Centres as it launches its "Principles and Minimum Expectation for Children Deprived of their Liberty". The Parliamentary Human Rights Committee wants to see action to reduce the need for restraint and separation, in all secure settings.

But it’s a third report- an inspection of the Young Offender Institution at Cookham Wood in Kent that shows the fundamental absurdity of locking up children in custody. Young people are brought together from across Southern England into an establishment where “complex and dynamic keep-apart restrictions that sought to keep numerous individuals away from each other had a serious detrimental impact on the services provided to young people and arguably the culture of the institution”.

In truth, there is a limited amount of new information or argument in any of the reports- how can there be when the shortcomings and contradictions of locking up children are so well known? If the parliamentarians are right that there are about two and a half thousand children in one type of detention or another in England and Wales, those on remand or under sentence – 834 at the end of February- nowadays account for only a third of them. As the ECI report says “the restriction of liberty is harmful to children, irrespective of their circumstance”, so more credit should arguably be given to youth justice practitioners for driving down the numbers in penal custody over the last ten years; and more attention should be given to the children locked up for other reasons and in other types of institutions.

Curiously, the End Child Imprisonment Coalition make no mention of the proposed Secure School which is due to open in Autumn 2020, a stone’s throw from Cookham Wood. Will it be part of the answer to phasing out prison custody or, like STCs, simply end up adding to the problem? The new school will be more than twice the size of ECI’s proposed maximum of 30 places; and it won’t be close to home for most of its residents. Whether it will meet other child care principles remains to be seen, perhaps soon - bids to run it  were due in by 1st of February.

Secure Children’s Homes are generally considered the most acceptable form of closed facility. They provide very much better levels of care than YOIs and STCs but even so are not immune from the deep- seated flaws common to all institutions. Recent inspections have found in one a particularly high number of sanctions of single separations for some young people “resulting in significant periods where young people would have been in their rooms on their own”. In another managers did not consistently critically assess the threshold for the use of physical restraint to make sure that this is required to protect young people, or others, from harm.

The Independent Inquiry into Child Sexual Abuse (IICSA) found 242 allegations made in secure children’s homes between 2009 and 2017- lower in absolute terms than were found in in YOIs (440) and STCs (297) but not necessarily when population is considered.   IICSA reported on the number of incidents of alleged sexual abuse as a percentage of the average population of STCs in 2016 but when I asked them to provide the equivalent data for each of the three types of secure institutions - STC, YOI and SCH- ideally for each of the years 2009-2017 or for the whole period, disappointingly they said they were unable to do so.

What all this suggests is that a much more vigorous strategy- and some fresh thinking - is needed to keep children out of institutions of all sorts. End Child Imprisonment want a system in which children should only be deprived of their liberty when they pose a serious risk to themselves or others, and there are genuinely no alternative options for mitigating that risk in the community. There are dangers of unintended consequences in a purely risk- based approach and some high threshold relating to harm already caused will be essential to prevent net widening. Where the Campaign is undoubtedly right is that “the duration of any episode of detention must be as short as possible”.

To achieve that, what’s needed is a recasting of secure custody not as any kind of end in itself but as a very short term means of planning community- based interventions. This should certainly be the approach for the 300 young people currently serving Detention and Training Orders and many of the 250 on remand. A different approach might be needed to those serving longer term sentences for grave crimes – particularly those who will be transferred into the adult estate when they reach 18.  
Back at Cookham Wood YOI, the inspectors found some young people, because of keep-apart restrictions, spent almost as much time each day being escorted to and from activity as they did in the activity. In their view “there needed to be some new thinking about how to challenge this restrictive culture and the causes of it”. They are certainly right about that.


Friday, 5 April 2019

Deja Vu All Over Again

The Justice Committee has produced a compelling report arguing that criminal justice is facing a crisis of sustainability, that prison is a relatively ineffective way of reducing crime and that the government should commit to a significant reduction of the numbers sent there.

This was their 2009 report Cutting Crime: the case for justice reinvestment significant parts of which resurfaced this week in the result of their latest inquiry “Prison Population 2022: planning for the future.” There’s nothing wrong with reprising what are by and large eminently sound conclusions. It’s always encouraging to read a cross party group of MPs state that “social problems cannot be meaningfully addressed through the criminal justice system” and that “there must be a focus on investing in services to reduce the £15 billion annual cost of re-offending and prevent offenders from continually returning to prison, thereby reducing the size of the prison population”

Had the incoming Coalition government implemented the recommendations from the earlier inquiry, we would not now have been “in the depths of an enduring crisis in prison safety and decency”. Will this week’s recommendations fare any better?

There must be some doubts.  First on the government side, when asked by MPs about his proposals for reducing short prison sentences – enthusiastically endorsed in the Committee’s report- Justice Secretary David Gauke said, “I do not think it can be sorted by the end of the year”. This is what officials call kicking a policy into the long grass. There must be long odds on Gauke still being in post by then and no guarantee that his successor will also hail from the Hurd/Clarke tradition of Conservative penal policy-making.

As for Parliament, the Committee wants MPs to look more closely at the impact on prison numbers when legislating. But while decrying an ever upward trend in sentencing levels, Justice Committee Chair (and member back in 2009) Bob Neill supported the 2015  Criminal Justice and Courts Act which did just that in respect of offences relating to possession of knives and causing death by dangerous driving.  
In terms of public attitudes, the 2009 report argued that means must be found for encouraging and informing sensible, thoughtful and rational public debate and policy development on the appropriate balance and focus of resources. This week we heard that “Greater transparency is necessary to enable the public and others to understand the true costs and the challenging and testing nature of decisions which need to be made about public spending on prisons.” There's not much evidence that an emphasis on costs is the best way of persuading people to reduce the use of prison. Nor does it seem a particularly propitious time for a "national conversation" about crime and justice- whatever that might entail.

More promising is the Committee’s argument that improving the sustainability of the prison population will require a review of sentencing legislation which should include the role of the Sentencing Council.  This week’s report quoted from evidence I submitted that the Council had not done enough to “challenge increasing sentence lengths, nor to give more explicit assistance to courts in determining when offences are so serious that only a prison sentence will do”.  Perhaps their current mandate does not permit them to do this- but when, as seems likely, the Justice Committee looks at the Council’s role this year -ten years after it was established- it should consider what more the Council should do to reduce prison numbers and promote community-based rehabilitation- both within its existing remit and with an expanded one.  

Monday, 18 February 2019

Sentence Planning: Why David Gauke Deserves Two Cheers

No one was quite sure what to expect from David Gauke this morning. Would we get some reheated (or under cooked) announcements to distract from the latest Ministry of Justice fiasco- in this case the Working Links probation company? Or was the Justice Secretary out and about as part of a government strategy to show that away from the joy of Brexit, domestic policy making is proceeding apace across Whitehall?

As it turns out, on this occasion at least, such cynicism was ill founded. It was to my mind the best ministerial speech on sentencing since Ken Clarke spoke at King’s College just after the 2010 election. Then, Clarke expressed incredulity that the prison population had doubled in the twenty years since he had previously held responsibility for it.

The Justice Secretary staked out a much more constructive way forward on the use of imprisonment than any of the four Justice Secretaries who’ve followed Clarke; by urging caution in continuing to increase sentence length as a response to concerns over crime; by arguing for switching resource away from ineffective prison sentences and into probation; and by starting  “a fresh conversation, a national debate about what justice, including punishment, should look like for our modern times”.

Since Clarke’s departure, policy has sought to focus much more on the practice of imprisonment than its use- with disastrous consequences. Prime Minister David Cameron didn’t want to “waste too much energy discussing big existential questions about the prison population.” As Justice Secretary, Liz Truss tried to paint England and Wales as “fairly mid table when it comes to custodial sentences” in comparison with other countries and argued that sentence inflation was limited to sexual and violent crimes.

Gauke rightly told his audience today that we are an international and historical outlier in terms of our prison population and that it’s not just about violent or sexual offences. “Prison sentences, in general, have been getting longer”.

So in terms of tone, his speech does mark an important break with recent history. Cameron described the idea that we could somehow release tens of thousands of prisoners with no adverse consequences as nonsense. Gauke sees “a very strong case to abolish sentences of six months or less altogether, with some closely defined exceptions, and put in their place, a robust community order regime”. 46,000 such sentences were imposed in the year to June 2018-more than half of all the prison terms passed.

Cameron promised you wouldn’t hear him “arguing to neuter judges’ sentencing powers or reduce their ability to use prison when it is required.” But that’s just what Gauke is planning.

Or is he? In the Q &A that followed the speech, it became clear that little has been decided in government but is rather being explored. As I have argued earlier there are difficult technical questions about achieving reductions in the use of short sentences. It’s the details that did for Ken Clarke’s efforts to reduce prison numbers – in his case the attempt to increase sentence discounts for early guilty pleas. So any penal reformers’ prosecco needs to stay corked for the moment.

The failings of the part privatised probation system will do little to assist Gauke’s ambitions, although the long-awaited arrival of GPS tracking- first announced as “prisons without bars” by David Blunkett in 2004- should increase options for monitoring community- based supervision. But it’s hard to see his promised shift in resources from prison to probation until the new services and structure come into place in 2021.

In the meantime, to build on his speech today, he should establish a review of sentencing as part of the national debate he wants about punishment in the modern age. Perhaps he could ask Justin Russell to lead it? 

He’s the senior MoJ mandarin who Gauke wants to succeed Glenys Stacey as Chief Inspector of Probation. Several people I spoke to at the speech this morning were uncomfortable with that appointment.   The independence of HMI Probation is of paramount importance and it simply doesn’t look right for an official who has been responsible for probation reform to lead the organisation. 

Saturday, 9 February 2019

The Wrong Trousers: Why The Tailored Review of the Sentencing Council Doesn't Measure Up

This week the Government published reports about four important organisations sponsored by the Ministry of Justice- the Law Commission, Criminal Cases Review Commission, Independent Advisory Panel on Deaths in Custody and the Sentencing Council. The reports are the fruits of so-called “tailored reviews”, which departments must undertake on all their arms- length bodies once every parliament. The reviews look at whether the outfits are still needed and how well they are working.

Up to now, the Sentencing Council has escaped the attentions of any government scrutiny because of its “unique role in maintaining the constitutional balance between the executive, legislature, and the judiciary”.  Such a role should arguably call for more not less examination, but anyway eight years on, there’s been a review of sorts. Sadly, it falls far short of what’s needed.

The review should have started by looking at what’s happened to sentencing since the Council started work in 2010. Eight years ago, if you were convicted of an indictable or either way offence- one of the more serious crimes- you had a one in four chance of going to prison. Now it’s one in three. Average sentence lengths have gone up too from less than 16 and a half months to over 20.   Since almost all the Council’s 25 Guidelines have generally sought to retain the current levels of sentence severity, on the face of it something’s gone wrong.

It’s possible that in recent years offences have become more serious and offenders more persistent- there is some evidence for that. But that’s far from the whole story. The Council’s own assessment of its guidelines on assault and burglary have shown they have resulted in unexpected increases in sentencing. Their assessment of theft guidelines, also published this week, paints a similar, if less pronounced picture.

Of the Council’s contribution to sentence inflation, you would learn nothing by reading the tailored review.   The review makes some useful recommendations - for the Council to consult more widely with black and minority ethnic groups in the production of guidelines for example - but the first order questions about the impact the Council has had, just haven’t been asked.

That’s the case as well with the Council’s remit to increase public understanding of sentencing. Is that any better than it was eight years ago? Not an easy question to answer but the review doesn’t even try- instead making an opaque recommendation that the Council “should consider widening public awareness of its work through cost-effective engagement with other criminal justice bodies”.

Part of the problem is that the review was somehow supposed, in true Sir Humphrey vein, to provide robust challenge with a light touch- and it’s the latter approach which has prevailed.  Cabinet Office Guidance says these tailored reviews should be appropriate for the size and nature of the organisation being reviewed and the significance of the organisation to the department. 

With a budget of £1.4 million, the Council is, in Whitehall terms, small beer. But its significance for the MoJ and its provision of prison places is much bigger. As an example, the introduction of the guideline on bladed articles and offensive weapons offences, which came into effect on 1 June 2018, is estimated to result in a need for around 80 additional prison places per year at a net cost of around £2.5 million. As a key driver of the MoJ budget, the Council deserves much greater attention than it's had.   

To be fair, back in 2017 the Council itself invited top Cambridge criminologist Tony Bottoms to review its work and it is making some changes as a result. But the Bottoms recommendations were limited to how the Council can best exercise its current statutory functions. My 2016 report for Transform Justice looked more broadly at what the Council should and could be doing if those functions were altered. I thought the House of Commons Justice Committee should conduct an inquiry into its role. But this tailored review might have done so too.

On Monday, alongside his announcements about  reconsideration of parole decisions, the Justice Secretary launched a tailored review of the Parole Board to examine further options for longer-term reform. He wants “to examine what further, more fundamental measures might be possible over the longer term, including the possibility of primary legislation. A tailored review of the Parole Board provides the opportunity to do that”.  

Much the same exercise is needed for the Sentencing Council.  Whoever did the tailoring of its review got their measurements wrong.

Monday, 4 February 2019

Challenging Times

Justice Secretary David Gauke has announced his plans for decisions made by the Parole Board to be challenged and looked at again. He should really have made a statement to Parliament about it - the Ministerial Code says that the most important announcements of Government policy should be made there in the first instance. But Gauke preferred the Sunday papers and Today programme for the latest episode in a saga stretching back to his first few days in office just over a year ago.  

In the media, Gauke was able to spin the plan as solely about giving victims the right to challenge release decisions and to gloss over the chance prisoners will have to ask for parole refusals to be reviewed too. In the new scheme, applications for a decision to be reconsidered will be open to the prisoner and the Secretary of State – the two parties to the Parole hearing- with victims able to make their representations for reconsideration via the Secretary of State. The Ministry of Justice estimates between 1% and 5% of release decisions will be challenged compared to between 13% and 16% of decisions to remain in custody which prisoners will ask to be reconsidered.

It’s anybody’s guess how many challenges will prevail on either side; and whether the possibility of review will make initial Parole Board decisions more conservative. Rightly, there’s no change planned to the grounds for the Board’s decision-making.  As the MoJ put it “Any detention beyond the minimum term imposed by the {sentencing} judge is not about ongoing punishment for the offences committed but about the offender’s current risk to the public by the time that stage of the sentence is reached – often many years after sentencing”.  

In the great majority of  cases, however strongly they may understandably feel about an offender’s release, victims have to accept that their views will have limited weight in assessing that risk. Welcome improvements to the arrangements for keeping victims informed and supported and the (limited) increases in transparency Gauke has introduced, cannot and should not, alter that central fact.    

Gauke has wisely resisted the temptation to allow members of the public or the media to apply for parole decisions to be reconsidered. The Government say they looked at the proposal to do so carefully, rejecting it as impractical, unworkable and unachievable without primary legislation.  Almost as an afterthought they make the principled point that “challenges should come from those with a standing and involvement in the case rather than from the public at large”.

This is a principle that arguably should be applied to the Unduly Lenient Sentencing Scheme which  was introduced 30 years ago last week.  It seems odd that in any case of an eligible offence, at the request of a single person, the Attorney General must decide whether the Court of Appeal should reconsider it. In 2017, 943 requests were received, of which 137 eventually had their sentences increased. 

When the ULS scheme started, a handful of cases a year were anticipated but its scope has gradually been extended down the years. It may be preferable to a generalised Prosecution right to appeal. But if  sentences for a yet wider range of offences are brought within the remit of the ULS,- as the current Attorney General seems to think desirable- there's an argument that only those who can demonstrate a sufficient connection to a particular sentence should be able to challenge it.   

As for Parole, after two MoJ reviews, a third is on its way, looking at the case for more fundamental reforms to the powers and responsibilities of the Board. If that case is made and accepted, and the Parole Board becomes more like a fully fledged court, the reconsideration mechanism announced today could turn out to be something of a short term expedient.    

Saturday, 12 January 2019

Six Months to Go

Last January, confronted with the disgusting conditions at HMP Liverpool, Prisons Minister Rory Stewart told MPs that the neglect of basics in prisons had resulted from too much talk “about grand issues of sentencing policy, reoffending and the policy context”.  A year on, Stewart feels compelled to indulge in just that talk himself, telling the Telegraph he is “looking very carefully” at  imposing a new legal presumption on English and Welsh courts against sentences under six months - and potentially longer. 

Stewart has come round to the view expressed by the Council of Europe after their 2016 visit to the UK that prison reform will be unattainable without concrete steps to significantly reduce the current prison population.  Also of course, many of the ten prisons on which his own ministerial performance will be judged in the summer have large numbers of short term prisoners. The case for dealing with most of them in the community has been very well made by the Revolving Doors Short Sighted campaign.  

So what happens now?   First, Stewart and boss David Gauke will have to persuade government colleagues to legislate for the necessary changes, and MPs to back them. In 2011, five newly elected Tory MPs wrote “It has been argued in the past that instead of short prison sentences, there should be a presumption against sending criminals to prison. We should take exactly the opposite approach and ensure that persistent offenders are imprisoned for prolonged periods of time”. All those expressing that view are current or former ministers. Stewart will have to win them over and hope for a following wind from Labour. It was Ed Miliband’s opportunistic attack on Ken Clarke’s progressive penal policy that killed of the last serious effort to reduce prison numbers eight years ago.

Second the Ministry of Justice will need to find the technical mechanisms to bring about the reduction of short sentences in practice. In Scotland, since February 2011 a court must not pass a sentence of imprisonment for a term of 3 months or less unless it considers that no other method of dealing with the person is appropriate. But five years on, in 2016/17, almost three and a half thousand people received such sentences including 750 for shoplifting and 689 for breach of the peace.   That year, these very short sentences still accounted for 28% of prison sentences compared to 34% before the presumption against their use. The overall number of custodial sentences has fallen from about 15000 to 12000 but this reflects a fall in court cases.  Yes, community sentences have risen, but many have probably replaced fines rather than custody. 

So Scotland may not provide the best model. The MoJ should look at other approaches too. One is to be more explicit about how serious an offence must be before courts can impose a prison term. There is no general definition of where the so-called custody threshold lies. While Sentencing Guidelines say that  “the clear intention … is to reserve prison as a punishment for the most serious offences”almost a thousand people were in prison at the end of March last year for shoplifting, 25 for theft of a bicycle and 11 for possession of cannabis. A higher hurdle is surely needed.  

Another problem is that courts must regard an offence as more serious if committed by someone with relevant previous convictions. Modifying this requirement so that courts may – but do not have to – punish repeat offenders more harshly is another route to consider.

A further option would be to encourage more suspended sentences. Currently, if the court imposes a term of imprisonment of between 14 days and 2 years, it may suspend the sentence for between 6 months and 2 years. Perhaps replace “may” with “must” other than where the interests of justice require immediate custody?  
I’d also like to see reinstated the principle that courts should take overcrowding and other painful realities of prison life into account when determining the punitive weight of a sentence.

A third task for the MoJ is to ensure that a wide range of properly resourced community-based measures are available and their availability communicated to courts. Problem- solving courts seem to have faded as a policy idea but if short sentences are to go, more, and more thorough, pre- sentence reports will be needed. So too perhaps a more systematic role for courts in reviewing the progress of sentences. The new probation contracts shortly to be let must take account of the MoJ' s new sentencing policy and provide resources to match it.

Earlier this week, the Chief Inspector of Probation wrote to the Justice Committee that  “with Brexit and other uncertainties, the proposed transition to new probation arrangements is not necessarily certain”.   Still less certain to be taken forward  perhaps are Mr Stewart’s grand issues of sentencing. They deserve to be. As was pointed out last year “Prison can become a ripe place for criminal education, serious and organised crime, and radicalisation, rather than rehabilitation”. By whom? No less than the National Police Chiefs Council.

Wednesday, 19 December 2018

Review of the Year (2) Prisons

Prisons minister Rory Stewart said today he wished he could lock MPs in the Commons chamber until they produced a positive consensus on Brexit. On reflection, yet another 650-place inner city Victorian jail is probably the last thing he needs in his day job- much as the public might at present support his sentiment. 

From the start of his tenure in January, when faced with explaining piles of rubbish, vermin infestations and degrading cell conditions at HMP Liverpool, Stewart and his boss David Gauke have certainly not ducked the challenge of trying to repair a ravaged prison estate, sensibly eschewing the high-flown rhetoric of their predecessors in favour of a back-to-basics campaign.  

At year end, Stewart told the Justice Committee he believed there are green shoots. Sadly, three weeks earlier, the Chief Inspector of Prisons told  a different tale. In July, Peter Clarke’s Annual Report had documented conditions which “have no place in an advanced nation in the 21st century.” By November, Clarke had seen nothing to give him optimism that any significant corner has been turned. “The violence figures are going in the wrong direction. We still see far too many drugs destabilising prisons. As to living conditions, I have not seen significant improvement in the prisons we inspect”.  

Of course, there should be improvements over time as staff numbers, so recklessly reduced earlier in the decade, increase and the new recruits that stick with it gain experience and confidence. The Inspectorate’s new Independent Reviews of Progress will hopefully document a more positive picture than we’ve seen in 2018- what Her Majesty might call an annus horribilis for her Prison and Probation Service.

Not surprisingly a whirlwind of initiatives has been announced during the year- and some are on the way to implementation. The revamped personal officer scheme (OMIC) has promise and the extension of in cell telephones could improve family contact and cut demand for illicit mobiles. More opportunities for release on temporary licence and enhanced living conditions for prisoners who engage with the regime could encourage positive behaviour as part of incentive schemes to be developed by governors rather than hq . Whether this can add up to a promised "rehabilitative culture" within establishments remains to be seen.

Already underway is the installation of new technology security solutions- airport-style scanners, body worn cameras, and phone-blocking. Dogs are used to patrol landings even in Category B prisons. There is a crackdown on crime in prison, with more prosecutions and tougher penalties for assaults on prison staff. 

In a recent case a prisoner in a Segregation unit pleaded guilty to three counts of administering a noxious substance for three separate potting incidents. Horrible of course, and I don’t know the details - but are three 10-month sentences served consecutively the only way of holding prisoners to account for this kind of behaviour?  More needs to be done to identify what lies behind it. In an investigation I did (published this year), I found debt in prison can be seen as a stone best left unturned by staff .

It’s not clear what’s become of promised changes to security categorisation aimed at isolating gang leaders from their followers. The rollout of PAVA spray looks to be on its way despite the Prison Reform Trust’s well-argued call for a rethink. It's a measure which owes as much to placating the demands of an increasingly frustrated POA as it does to  the success of the pilot scheme. 

In terms of resettlement, the challenges remain enormous. The Employment Strategy reports success in attracting business interest in taking on ex offenders and post Brexit gaps in the labour market could offer opportunities to people coming out of prison. Measures have also been announced to reduce shocking levels of homelessness and rough sleeping though currently limited to pilot sites.  At HMP Leeds, half of prisoners said in the Inspectorate’s survey this year they weren’t getting the help they needed to sort out accommodation, employment and finance on release.  Somehow, the inspectors rated outcomes on rehabilitation and release planning as reasonably good. 

To help fix this, a relaunched Through The Gate service should see 500 extra resettlement staff across all resettlement prisons in England and Wales. Yet the Prison Service cant seem to find a way to avoid the basic difficulties, highlighted by NACRO , created by  releasing prisoners on a Friday. 

2018 saw confirmation that two new men’s prisons will be built at Wellingborough and Glen Parva, both to be run by the private sector. These will provide more than 3,000 places out of a promised total of 10,000 in the new for old estate modernisation programme  Despite the debacle at HMP Birmingham which saw the prison service step in to run it in August, the Government has announced a Prison Operator Services Framework competition suggesting that the private sector will continue to play an important role -under a Conservative government at any rate. The Justice Committee’s hearing into what went wrong at Birmingham is a poor substitute for the full independent assessment  recommended by Peter Clarke. The assertion by former Justice Minister Phillip Lee that “companies are currently ripping off taxpayers” also needs proper investigation.

June’s long awaited Female Offender Strategy thankfully scrapped plans for small women’s prisons but pledged only a small proportion of what they would have cost to fund alternative residential centres. 

Should we expect something similar in respect of plans for new men’s prisons in the light of lower than expected prison population projections and higher pressures on the MOJ budget? There is certainly  case for a much wider range of custodial, residential and community-based options than currently exist for those remanded for or convicted of offences.

Back in January, two weeks into the job, Rory Stewart told the Justice Committee that

“If I am not able in the next 12 months to achieve some improvements in making these prisons basically clean, with more fixed broken windows and fewer drugs, I am not doing my job, and I would like you to hold me to account for that in 12 months’ time”.

Sensibly he subsequently bought himself more time (until August 2019) and specified ten prisons on which to be judged. Its HMPPS Chief Michael Spurr who’ll be leaving in the New Year.  Will Stewart be following him out of the gate?