Matt Vickers
MP for Stockton West · Conservative · United Kingdom
“Q In your experience, how often does article 8 make the decisive difference between somebody being allowed to remain or being removed? Do you think that the provisions in the Bill will materially and effectively change that situation?”
“Q Minister, the independent Regulatory Policy Committee has rated the Government’s impact assessment of the Bill as not fit for purpose. It says: “Little of the appraisal is quantified and most impacts are…uncertain.” What measurable difference do the Government expect the Bill to make? How many additional removals will it deliver?”
“Q With regards to the article 8 changes, can you give us one concrete example of a category of case where someone could successfully resist removal today on article 8 grounds, but where the Bill would prevent them from doing so in future? Anna Turley: Bas, you have an example—we discussed this earlier today.”
“I know we have recently had an increase, but if we want to get rid of the backlog, we are going to have to address the larger numbers of people coming into the system with no representation at all because they cannot find a lawyer. Most legal aid lawyers cannot make this work on the rates, so they are giving up.”
“Q To get the result that we want—tackling that abuse—what else should the Home Office be doing in that space? If this is not a solution, what would you put forward as an alternative, if that abuse does exist?”
“The current system was not designed to cope with a world that is so volatile and insecure, or with people travelling through multiple safe countries before crossing the channel, particularly by boat. We have to confront the situation facing our asylum system, which is one of the most permissive, compared with other countries in Europe.”
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“Those carve-outs are designed to safeguard industries with genuine operational needs for such technology, while still targeting the widespread abuse seen in mass-messaging scams, SIM box fraud and illegitimate telecommunications activity. The clause is a key part of the broader effort to close regulatory gaps and strengthen the legal tools available to tackle modern digital fraud. Clause 81 makes it a criminal offence to supply a SIM farm to another person. Clause 82 offers a meaningful definition of what constitutes a SIM farm for the purposes of clauses 80 and 81, and provides the Secretary of State with the power to amend the definition by regulation. Schedule 10 provides for powers of entry and other investigatory powers relating to offences involving SIM farms.”
“Clause 80 introduces the new criminal offence of possessing a SIM farm, reflecting growing concerns about their misuse in fraudulent and criminal activity. The clause makes it an offence for an individual to possess such a system unless they can demonstrate that they have a lawful authority or good reason for doing so. That shifts the burden to the defendant to prove the legitimacy of their possession, aiming to deter misuse while protecting legitimate operations. The clause also provides examples of what may constitute a good reason, including the use of SIM farms for broadcasting services, public transport operations, communications network maintenance or freight tracking.”
“Mobile UK further warned that the proposed measures would not eliminate large-scale spam or scam messaging, and urged the Government to broaden the definition of SIM farm to include software-based or e-SIM-enabled methods used to achieve the same fraudulent outcomes. In the Criminal Justice Bill in the 2023-24 Session, the previous Government included provisions to criminalise the possession or supply of devices capable of holding five or more SIM cards, targeting the infrastructure used in large-scale scams. I welcome the Government’s carrying forward the provisions in the Criminal Justice Bill to amend the definition of SIM farm and prohibit other electronic devices used to commit fraud via secondary legislation.”
“They subsequently launched a consultation on how best to implement the ban, although, interestingly, there were only 50 responses, many from businesses or individuals identifying as legitimate SIM farm users who opposed a ban. In response to the 2023 Home Office consultation on SIM farms, Mobile UK, the trade body representing the UK’s four major mobile network operators, raised concerns that the proposed ban risked being ineffective due to evolving fraud tactics and technological advancements, including the fact that single-SIM devices, rather than SIM farms, are now the most common tools used to send spam SMS messages, according to data from one mobile operator.”
“These figures demonstrate the persistent and pervasive threat posed by scam communications, underlining the urgent need for more robust protections and enforcement mechanisms to safeguard the public. SIM farms pose serious risks to national security and digital infrastructure. Their use can lead to network congestion, overwhelming mobile networks and disrupting legitimate communications. More critically, they are often exploited by organised crime networks to co-ordinate illegal activity as they are cheap, disposable and difficult to trace. That makes it significantly harder for law enforcement to monitor communications or link messages to specific individuals. The previous Conservative Government committed to banning SIM farms as part of their fraud strategy announced in May 2023.”
“They are also frequently used to bypass verification systems by creating large numbers of fake accounts on social media, messaging apps or online services. In other cases, SIM farms are employed in SIM box fraud, a scheme in which international calls are rerouted and disguised as local calls, depriving telecom providers and Governments of revenue and making the original caller harder to trace. According to research carried out by Ofcom in August 2022, the scale of nuisance and potentially fraudulent communications across UK mobile networks remains alarmingly high. An overwhelming 75% of mobile users reported receiving suspicious texts or calls in just a three-month period, highlighting the widespread nature of the issue.”
“A SIM farm is a system used to manage and operate a large number of SIM cards simultaneously, often using multiple mobile devices or modems controlled by central software. Farms can contain hundreds or even thousands of SIM cards, and they are typically used to send or receive a high volume of messages, calls or mobile data across networks. While there can be legitimate uses for SIM farms, such as in telecoms testing or large-scale communication platforms, they are commonly associated with illicit and fraudulent activities. One of their most concerning uses is in the spread of spam and phishing texts, where mass messages with links to scams or malware are sent to unsuspecting individuals.”
“I would be grateful if the Minister set out what safeguards are in place to ensure that the designation power is not applied disproportionately or used to deter legitimate protests. How will the police ensure that adequate and timely public notice is given to protestors or members of the public who may enter a designated area unknowingly? Will the Minister clarify how long written records of designations and directions would be retained, and whether they would be publicly accessible for scrutiny and accountability? Will there be a requirement for post-event review of designations and use of these powers to assess their proportionality and impact?”
“Clause 87 sets out the powers available to senior police officers to designate a specific locality in England or Wales where the offence of concealing identity at protest will apply. It allows for the designation to be made for up to 24 hours if it is reasonably believed that a protest is happening or is likely to happen in the area, that it may involve criminal activity, and that it is necessary to limit or prevent such offences. The clause further sets out how the designation can be expanded and provides for the British Transport police and Ministry of Defence police to apply similar designations within their jurisdictions. Clause 88 sets out the requirements and procedures around creating such designations.”
“Clause 86 rightly introduces a new offence aimed at individuals concealing their identity while attending public protests in designated areas. It recognises and provides for certain legitimate reasons that a person might have for covering their face, including those related to health, religious observance or occupation. It also rightly sets out obligations on the authorities to ensure public awareness of the rule when it is in effect, as well as the sanctions for those who fail to comply. The clause sends a clear message that protest should be lawful, peaceful and safe. When used appropriately and with the public properly informed, the measure could greatly enhance the safety of both demonstrators and the wider public by discouraging those who intend to use anonymity as a cover for criminal acts.”
“That incident was part of wider unrest across the UK, prompting investigations by law enforcement. My hon. Friend the Member for Windsor has ably set out the purposes and benefits of amendment 51, which seeks to provide a framework requiring those concealing their identity to provide advance notice. We heard during our evidence sessions about the legitimate reasons why people may wish to conceal their identity, and we are also aware of the need to protect the public from those who exploit such concealment to do harm to others. The amendment could provide a great opportunity for law enforcement to assess and monitor situations properly, offering a more flexible and accountable approach to managing exemptions. Does the Minister feel there could be enforcement benefits to having a more flexible power to assess the use of face coverings?”
“We are all too familiar with those who use protests and the anonymity of face coverings to commit criminal acts and intimidate others. When individuals conceal their identity, whether through masks, scarves or other objects, it becomes much harder for police to identify suspects involved in criminal activity such as violence, vandalism or intimidation. That anonymity can embolden a small number of individuals to commit offences, in the belief that they will not be held accountable. In 2024, masked individuals were reported to have attacked police officers in Rotherham during protests, leading to discussions about banning face coverings at such events. Members might recall that in Birmingham, a group of men wearing balaclavas and waving Palestinian flags stormed a pub, assaulted a patron and caused property damage.”
“The Metropolitan police described the actions as inflammatory, but noted that at the time no specific law prohibited climbing on war memorials, so no arrests were made. The introduction of the offence reflects growing public unease about the perceived disrespect towards war memorials during certain protests in recent years. It is right that this measure should be put in place to protect the memory and legacy of those who made the ultimate sacrifice.”
“The clause introduces a new offence targeted at individuals who climb on designated war memorials without lawful justification. It is designed to protect sites of national remembrance and ensure that they are treated with appropriate respect and dignity. The act of climbing on such memorials, often during protests or large gatherings, can be seen as disrespectful, provocative or even intentionally inflammatory, particularly when shared on social media. For example, at a pro-Palestinian demonstration in London in 2023, a group of protesters climbed on to the Royal Artillery memorial at Hyde Park Corner, which honours the tens of thousands of Royal Artillery soldiers who died in the first world war.”
“The involvement of a judge, strict criteria for suspension, and provisions for variation or appeal ensure a fair balance between enforcement and civil liberties.”
“The clause rightly provides a legal framework for suspending IP addresses and domain names linked to serious crime. This is a valuable measure in the fight against cyber-enabled criminal activity, including fraud, child exploitation and unlicensed online gambling. By allowing appropriate officers to apply to a judge for a suspension order, the clause ensures that access to digital infrastructure used for criminal purposes can be swiftly and lawfully disrupted. It will be particularly effective in cases where traditional enforcement is difficult because of the borderless nature of online platforms. Crucially, safeguards are built in to ensure that the powers are used only when necessary, and proportionately.”
“Will the Minister comment on the rationale for narrowing the scope of the powers being given to our police by this measure?”
“It seems like a common-sense measure that will allow law enforcement to act swiftly in recovering electronically tracked stolen goods, making it a highly effective tool in the fight against crime. When stolen items are equipped with tracking devices, the ability to bypass the often time-consuming process of obtaining a warrant can be crucial in preventing further harm, such as the sale or distribution of the goods. The clause will ensure that officers can quickly respond to real-time data, reducing the window of opportunity for criminals to move or hide stolen goods. The clause adopts a narrower approach to these powers than that proposed by the Criminal Justice Bill. I have always been of the view that, wherever possible, we should look to further enable our police officers and law enforcement agencies to tackle crime.”
“Clause 93 is hugely important and rightly allows the police to search premises for electronically tracked stolen goods without a warrant, offering a fast and efficient way for the police to recover stolen items before they are further distributed or sold, with the clause defining the authorisation procedures and limitations on the powers. The clause empowers senior officers at the rank of inspector or above to authorise searches based on reasonable grounds and electronic tracking data. This is particularly useful in cases where obtaining a warrant in time could risk losing crucial evidence or missing the opportunity to seize the stolen goods. It is designed to enable law enforcement to act quickly when there is clear electronic tracking evidence that stolen goods are present on the specified premises.”
“I welcome the Minister’s comments on the role of facial recognition technology and on the safeguards put in place to ensure the power is not used disproportionately or inappropriately.”
“Clause 95 updates and expands police and law enforcement access to driver licence data held by the DVLA. It replaces the existing section 71 of the 2000 Act with a revised framework, adding proposed new sections 71A and 71B. The modernised provision allows authorised individuals including the police, service police and other specified law enforcement bodies to access driver licensing information not just for road traffic offences but for a wider range of policing and law enforcement purposes. The Secretary of State is given power to regulate access, impose conditions and consult relevant bodies before issuing new rules or codes of practice. The clause also introduces oversight measures, such as a statutory code of practice and an annual report to Parliament, ensuring transparency and responsible data use.”
“Sections 9 and 10 of the 2005 Act, which govern the process for initial and follow-up assessments following a positive drugs test, are amended to refer to specific controlled drugs rather than just class A substances.”
“The clause also inserts new schedule 2B into PACE to define the list of trigger offences, replacing the outdated schedule 6 of the Criminal Justice and Court Services Act 2000. The updated schedule retains many existing offences, particularly theft and drug offences, but removes fraud and vagrancy offences. It adds a range of new offences such as common assault, certain violent crime and public order offences. The Secretary of State is given the power to amend the list of drugs and offences through regulations subject to either the draft affirmative or negative resolution procedures, depending on the nature of the change. Clause 97 makes related changes to the Drugs Act 2005 to align the drug assessment framework with the new expanded testing regime.”
“Clause 96 and schedule 13 significantly expand the existing powers of the police to conduct drug testing on individuals in detention. Currently, the police can test only for class A drugs under certain conditions. The clause amends sections 63B and 63C of the Police and Criminal Evidence Act 1984 to enable testing for any specified controlled drug, broadening the scope beyond class A to include class B and C substances. The change allows for testing following arrest for those aged 18 and over, or charge for those aged 14 and over, where the arrest relates to a trigger offence or where a police inspector reasonably suspects that drug misuse contributed to the offence.”
“The clause expands the definition of a “relevant foreign offender” in both the Criminal Justice Act 2003 and the Police, Crime, Sentencing and Courts Act 2022, to include individuals who have limited leave to enter or remain in the UK as defined by the Immigration Act 1971. By doing so, it ensures that people with limited immigration status are treated as relevant foreign offenders for the purposes of issuing conditional or diversionary cautions, enabling those cautions to carry immigration-related consequences, such as potential removal from the UK. Question put and agreed to. Clause 101 accordingly ordered to stand part of the Bill. Clause 102 Confiscation Question proposed, That the clause stand part of the Bill.”
“I would be grateful if the Minister would tell us what mechanisms would ensure that enforcement authorities could be held accountable if acting unreasonably, dishonestly or improperly during civil recovery proceedings.”
“The court is prohibited from making such orders unless the enforcement authority acted unreasonably, dishonestly or improperly during the proceedings. Proposed new section 288A(1)(c) of the 2002 Act introduces a discretionary power for the court to determine if, in unforeseen circumstances, it would be just and reasonable for an enforcement authority to pay costs. This provision acknowledges that civil recovery orders, which result in the permanent deprivation of a person’s property, engage the right to peaceful enjoyment of possessions. It ensures that the enforcement process complies with the right to access to a court, as guaranteed by article 6 of the European convention on human rights.”
“That ensures that the confiscation amount reflects only the actual benefit derived from crime and prevents double counting of assets that have already been returned or forfeited. In the light of the changes introduced in clause 102 and schedule 14 on criminal lifestyle provisions, can the Minister clarify how the new flexibility in prosecutorial discretion will ensure that limited resources are effectively allocated, while safeguarding the fairness of confiscation proceedings for defendants who may not meet the criteria for a criminal lifestyle? Clause 103(1) inserts new section 288A into part 5 of the Proceeds of Crime Act 2002. This provision aims to protect the enforcement authorities from being ordered to pay costs in civil recovery proceedings conducted in the High Court.”
“Previously, the law required at least three offences to qualify, but this change reduces that threshold to two offences. That will also apply if the defendant has benefited or intended to benefit from the criminal conduct involved in the offence, making the test easier to meet and broadening the scope of the confiscation regime. A significant reform is found in paragraph 6, which amends section 7 of POCA to clarify how the value of the recoverable amount should be calculated. Currently, certain categories of property are ignored when calculating the value of a defendant’s benefit from crime, including property that has been forfeited or is subject to a recovery order. The proposed amendment extends that to further categories of property, such as property seized under any rule of law and property returned to victims.”
“The principal aim as defined in section 5A(2) is “to deprive the defendant of the defendant’s benefit from criminal conduct, so far as within the defendant’s means.” That will help to ensure that confiscation powers are used proportionately and in line with the objectives of the law, addressing gaps in case law and providing a clear framework for the court. Paragraph 2 of schedule 14 now allows the prosecutor to decide whether to pursue a criminal lifestyle assessment rather than automatically applying it. That change allows for more flexibility in the application of these provisions, enabling prosecutors to allocate resources more efficiently and only pursue the criminal lifestyle route where appropriate. Paragraph 4 introduces a change to the test for determining whether an offence constitutes part of a defendant’s criminal lifestyle.”
“Clause 102 reforms the Proceeds of Crime Act 2002, aiming to clarify and strengthen the confiscation regime for proceeds of crime in England and Wales. Schedule 14 outlines several significant amendments with the primary goal of improving the effectiveness and fairness of confiscation proceedings. One key change introduced by schedule 14 is the insertion of section 5A into the 2002 Act. The new section provides an overarching principal objective, which has been lacking, for the confiscation powers under part 2.”
“That is especially significant where there are concerns about future harmful behaviour, even if the original offence did not relate to sexual offending. The clause provides tools to manage individuals involved in terrorism-related offences, helping authorities gather intelligence and make informed decisions on their supervision. It also promotes consistency and supervision, as polygraph conditions are already used for sexual and terrorist offenders, ensuring a balanced approach to risk management across high-risk groups. What safeguards ensure that the Secretary of State’s discretion in determining risk is transparent and fair? Given that polygraph evidence is not admissible in trials, why is it being increasingly used as a post-sentence supervision condition?”
“Clause 104 broadens the use of polygraph testing for offenders by amending the Offender Management Act 2007. It allows polygraph testing for individuals convicted of murder upon release if they pose a risk of committing a sexual offence, and are 18 or over. It also applies to offenders who have served time for a relevant sexual offence, provided they are 18 or older at release. Additionally, the definition of “relevant offence” is expanded to include terrorism-related offences, including those committed for terrorist purposes. The provision functions as a preventive safeguard. Polygraph testing can act as a deterrent, encouraging compliance with licence conditions or reminding offenders that their conduct and disclosures will be monitored.”
“The overarching aim of the clause is to close a monitoring gap by ensuring that responsible authorities are kept fully informed of how to reach the offender. That is particularly important for managing compliance with rehabilitative requirements and preventing individuals from circumventing supervision through undisclosed identities or means of communication. Will the Minister clarify what threshold is intended by the term “reasonably practicable” in this context? Given that it is open to interpretation, will statutory guidance be issued to ensure consistent application by youth offender panels and responsible officers?”
“Clause 105 requires certain offenders, including those under referral orders, youth rehabilitation orders, community orders and suspended sentence orders, to provide up-to-date contact information to relevant authorities. Offenders must notify their responsible officer or panel member of any changes in names, phone numbers or email addresses as soon as reasonably practicable after the relevant order is made or after they begin using new contact details. For youth offenders under referral orders, the clause adds a new section to the sentencing code, mandating them to inform a youth offending team member of any aliases and their current contact details as soon as reasonably practicable. Similar requirements apply to offenders under future and existing orders.”
“Met commissioner Sir Mark Rowley welcomed the reforms, citing the need for greater control to uphold standards. However, the Police Federation criticised the changes, warning they could undermine fair hearings and lead to excessive influence by chief officers, risking biased outcomes.”
“It demonstrates that law enforcement and oversight bodies are committed to transparency and integrity. What safeguards are in place to prevent inappropriate or premature referrals to the Director of Public Prosecutions under this accelerated procedure? How will the IOPC or other appropriate authority be held accountable for determinations made? Currently, chief officers have no right of appeal against panel decisions and may only challenge outcomes via judicial review. In October 2022, the Government launched a review of the dismissal process, with findings published in September 2023. Recommendations included a presumption of dismissal for gross misconduct; automatic gross misconduct designation for certain convictions; streamlined performance and vetting-based dismissal processes; and a new appeal right for chief officers.”
“Clauses 106 to 108 implement these proposals, which had previously been tabled as amendments to the Criminal Justice Bill. Clause 106 introduces significant procedural reform to allow certain criminal investigations into police misconduct to be expedited. It is clear that the clause will help to significantly speed up accountability, especially in cases involving clear and serious misconduct by police officers. By allowing criminal proceedings to be brought sooner, it reduces the delay in holding individuals accountable for their actions, ensuring that justice is not unduly postponed. In situations where there is clear evidence of misconduct, that allows for quicker action. A quicker response can help to reassure the public that, where there are serious allegations, the authority is acting swiftly and decisively.”
“On 5 September 2022, an armed police officer shot and killed Chris Kaba during a vehicle stop in south London. The police referred the case to the IOPC, as required when someone dies or is seriously injured in police custody or contact. The IOPC investigated and referred the case to the Crown Prosecution Service, which authorised a murder charge in September 2023. Concerns over accountability systems led the Home Office to launch a review in September 2023. In March 2024, the officer was identified and the Home Secretary announced three immediate changes to improve accountability: raising the threshold for CPS referrals; relaxing restrictions on criminal proceedings; and formalising victims’ rights under the IOPC’s victims’ right to review policy.”
“It ensures that authorities have up-to-date information regarding the young person’s school involvement, which can be a crucial element in their rehabilitation. How will the Government ensure that the notification requirements, particularly educational details, do not inadvertently stigmatise the young person, or disrupt their education experience, especially in cases where the individual might already be vulnerable or at risk of exclusion from school?”
“The order may give rehabilitation, counselling or other interventions designed to steer the individual away from terrorism-related conduct. Clause 111 defines serious harm in the context of YDOs. New clause 61 introduces notification requirements for a youth diversion order, where the respondent must notify the police within three days of being served with the order. The notification includes personal details such as the respondent’s name, any additional names, home address, and the name and address of any educational establishment the respondent normally attends. It is intended to help ensure the youth’s compliance with the order, as well as assist in tracking their progress or risk of non-compliance. This approach strengthens the monitoring aspect of YDOs by tying in an educational component.”
“The new youth diversion orders are designed as a counterterrorism risk management tool for individuals under the age of 21. The purpose of the YDOs is to divert young people from engaging in terrorist activities, and to allow police to intervene at an earlier stage. Clause 110 grants the police the authority to apply to the courts for a YDO. Clause 110 clarifies that a YDO can be applied for by a chief officer of police when the respondent meets certain criteria based on their age and involvement in terrorist-related offences. In England, Wales and Northern Ireland, the respondent must be between the ages of 10 and 21, and in Scotland, between 12 and 21. The aim of the order is diversion, rather than punishment. The YDO is intended to help prevent further involvement in terrorism or related activities.”
“How will the Government ensure that YDOs do not interfere with religious or cultural practices of respondents, as the clause provides, especially when it comes to limitations on association or communication?”
“This would ensure that the protective measures stipulated in the order were maintained throughout the duration of the individual’s involvement in the diversion programme, offering ongoing protection to the public while allowing continued monitoring of the individual’s risk level. The amendment would ensure that the diversion process is both effective and responsive to the changing nature of extremist behaviour, and that any decision to conclude or extend the order is based on robust and independent expert evaluations, thus improving the overall effectiveness of the youth intervention measures in countering extremism and terrorism. Clause 112 outlines the content and conditions of a youth diversion order, providing the framework for how the order can be structured and what it can include.”
“If the individual was assessed to be still holding extremist views or continuing to pose a terrorism risk, the youth offending team or a chief officer of the police would have the power to apply to the court for an extension of the youth diversion order. This extension could be granted for an additional 12 months, allowing continued intervention and monitoring of the individual. Importantly, the extension would ensure that the order remained in place for as long as the individual was considered to pose a risk to public safety. Finally, the amendment specifies that all provisions, prohibitions and requirements set by the YDO will remain in effect until the individual has been assessed as holding no extremist views or posing no terrorism threat.”
“A critical element of the amendment is the requirement that qualified experts carry out the assessment. The evaluation of whether the individual continues to hold extremist views or to present a terrorism risk must be conducted by an expert in extremism and counter-terrorism. This would ensure the assessment is informed by a high level of expertise and understanding of the complexities of radicalisation. Assessments made by the youth offending team must be reviewed by an external expert who has no pre-existing relationship with the respondent. This independent review would guarantee objectivity and minimise any potential bias in the evaluation process.”
“Amendment 40 primarily focuses on the duration, assessment and possible extension of YDOs, and it would ensure that the orders are subject to review and that further intervention is applied when necessary. Under the amendment, YDOs must specify a period of up to 12 months in which the young person is monitored and guided through the diversion programme. This would ensure there is a clear time limit with a defined end point for the intervention. Additionally, before the order concludes, an assessment must be carried out to evaluate whether the individual continues to hold extremist views or poses a terrorism threat. This would add an important safeguard to the process, ensuring that young people who may still be a risk are identified before the order ends.”
“The clause allows the courts to impose interim measures to temporarily manage a respondent’s behaviour, safeguarding public safety, while the full process is ongoing.”
“This provision is significant because it allows for situations in which immediate intervention is necessary and the respondent is not notified before the application is made. How will the Government ensure that respondents’ rights are protected in cases where an application is made without notice? What measures are in place to prevent misuse of this provision? Clause 115 makes provision for an interim youth diversion order to be made during the adjournment of a hearing for a full YDO. It ensures that even while a decision on the full application is pending, the court can take immediate temporary action to manage the respondent’s risk, particularly in cases involving potential extremism or terrorism.”
“Clause 113 outlines the duty to consult before making an application for a youth diversion order or the variation or discharge of such an order, particularly when the individual involved is under 18. It ensures that key stakeholders are involved in the decision-making process, so that the young person’s best interests are taken into account, and it ensures that the relevant agencies are informed and consulted before any formal application is made. How do the Government plan to ensure that the agencies that are consulted—in particular the youth offending teams—have the necessary expertise and resources to adequately assess the case before the application for a YDO is made? Clause 114 outlines the process for making an application for a youth diversion order without notice to the respondent.”