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EC v Birmingham and Solihull Mental Health NHS Trust  | 
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| Issue:  | 
Whether it was possible to appeal the failure of a Tribunal not to make an extra-statutory recommendation as to transfer or leave in the case of a restricted patient or the failure to give reasons as to the absence of such a recommendation. | 
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| Court:  | 
Upper Tribunal (AAC) | 
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| Reference:    | 
HM/3053/2011 and HM/3502/2011 | 
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| Neutral Citation:    | 
[2012] UKUT 178 (AAC) | 
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| Judge(s):  | 
UTJ Rowland | 
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| Date:  | 
29 May 2012 |