Recommendation 24

Given the current capacity of the immigration estate and limited scope for removals to third countries, we share concerns that detaining greater numbers could give rise to the need to use unsuitable facilities, with risks for human rights. Abandoning many of the limitations and safeguards against inappropriate or unjustified detention, particularly for children, families and pregnant women, increases the likelihood that these rights will be infringed. If these detention powers remain within the Bill, it should be amended to retain existing limitations and safeguards regarding the detention of vulnerable groups (see Annex, Amendment 14).