Facts: NM had a significant learning disability and was in prison. The Parole Board had made directions about the making of MAPPA (multi agency public protection) arrangements but no such arrangements had as yet been initiated. NM sought a community care assessment from Islington, so as to inform the Parole Board as to what support would be available to him on release. Islington declined to undertake such an assessment.

Judgment: Sales J held that, since no relevant MAPPA process had as yet been undertaken, the prospect of NM’s release was as yet too speculative for the duty to assess to arise. A duty would arise when the Parole Board takes a decision in principle that someone should be released and, also, when there has been a full MAPPA consideration with an indication that community care services would be likely to be required and the Parole Board needs more information about that.

Comment: nothing in the Care Act 2014 seems to displace this somewhat restrictive approach.