{"id":561720,"date":"2026-04-14T22:45:11","date_gmt":"2026-04-14T20:45:11","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/lee-gary-brown-v-the-charity-commission-for-england-and-wales\/"},"modified":"2026-04-14T22:45:11","modified_gmt":"2026-04-14T20:45:11","slug":"lee-gary-brown-v-the-charity-commission-for-england-and-wales","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/lee-gary-brown-v-the-charity-commission-for-england-and-wales\/","title":{"rendered":"Lee Gary Brown v The Charity Commission for England and Wales"},"content":{"rendered":"
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A. Background 1. On 20 September 2018, the Appellant pleaded guilty to three counts of rape of a child under 13, one count of attempted rape of a child under 13 and one count of sexual assault of a child under 13. On 31 October 2018 he was sentenced to a period of imprisonment of four years. Consequently, the Appellant was made subject to indefinite notification requirements in accordance with sections 80, 82 and Schedule 3 of the Sexual Offences Act 2003 (\u201cthe 2003 Act\u201d). The Appellant\u2019s period of imprisonment ended in 2020 and his licence period concluded in 2022. The Appellant will be eligible to seek a review of the indefinite notification requirements pursuant to Schedule 3A of the 2003 Act in 2035. 2. By virtue of the indefinite notification requirements to which he is subject, the Appellant is automatically disqualified from being a trustee for a charity and\/or from holding an office or employment in a charity with senior management function under s.178 of the Charities Act 2011 (\u201cthe 2011 Act\u201d). 3. The Appellant is an employee of a penal reform charity, the Howard League for Penal Reform (\u201cHLPR\u201d), working first as a Research Fellow from June 2022 before securing a permanent appointment as Operations Co-ordinator in September 2022. The Appellant is also a Voluntary Adviser to the East London Metropolitan Opera (\u201cELMO\u201d), registered charity number 1185310. ELMO\u2019s current objects are: 1) To advance, improve, develop and maintain public education in, and appreciation of, the art and science of music in all its aspects by any means the trustees see fit, including through the presentation of public concerts and recitals; 2) to provide facilities which promote the practice or enjoyment of the art of music for recreation or other leisure time occupation and to make them available in the interests of social welfare to individuals who have need of such facilities by reason of their youth, age, infirmity or disablement, financial hardship or social and economic circumstances or for the public at large with the object of improving conditions of life. 4. In October 2023the Appellant was introduced, on referral by the HLPR, to ELMO\u2019s board of trustees as a potential new trustee with lived experience and other relevant qualifications. Following that meeting ELMO\u2019s board agreed that they wished to invite the Appellant to be a trustee at ELMO subject to the Appellant obtaining a waiver to his disqualification from the Charity Commission. 5. On 06 November 2023, the Appellant applied to the Charity Commission (\u201cthe Commission\u201d) for a waiver from automatic disqualification under s.181 of the 2011 Act to serve as a trustee for ELMO and a general waiver of the disqualification in relation to a class of charities described as penal reform charities. The Commission refused both applications in separate decisions dated 17 December 2024 on the basis that in their view the factors in favour of granting either waiver did not outweigh the risks. 6. The Appellant submitted a Notice of Appeal against each of those decisions to the Tribunal on 07 January 2025. Following agreement by the Parties, a Registrar of the Tribunal directed that these appeals be joined together and stayed pending the outcome of an internal Decision Review by the Commission. On 15 August 2025, the Commission maintained their refusal of both applications. It follows that these appeals are now against the decisions of 17 December 2024 and the review decision of 15 August 2025. B. The Hearing 7. This appeal was listed for a one-day face to face hearing at Field House which took place on 10 February 2026. The Appellant attended and represented himself at the hearing. The Appellant\u2019s parents attended the hearing to observe and support him. Two witnesses attended for the Appellant: Victoria Holt Eze, Chair of the Board of ELMO and Andrea Coomber, Chief Executive, HLPR. Neither witness had provided a statement in advance of the hearing but with the agreement of the Parties and the Tribunal the witnesses adopted their letters of support dated 20 January 2024 and 30 October 2025 as their evidence in chief in addition to oral evidence given at the hearing and under cross examination. It was clarified during the course of Ms Coomber\u2019s evidence that despite her significant experience of working within the penal reform sector, her evidence was not that of an expert witness. 8. The Commission was represented at the hearing by Felix Rechtman. Joanne Maguire, Senior Case Manager and reviewing decision maker attended as a witness for the Commission. Joanne Maguire adopted her witness statement of 24 October 2025 as her evidence in chief and answered questions from both the Appellant and the Tribunal. A number of observers for the Commission also attended but played no part in the hearing. 9. Enquiries were made with the Appellant at the commencement of the hearing as to any reasonable adjustments that may be required in order to facilitate participation and the Appellant confirmed he did not require any adjustments. It was explained that there would be breaks in the proceedings but if the Appellant required a further break that could be facilitated. C. The Law 10. Part 2 of the 2011 Act contains provisions for the functions of the Commission including its objectives (s.14), general functions (s.15) and general duties (s.16). 11. S.178 of the 2011 Act (so far as relevant) provides: (1) A person (\u201cP\u201d) is disqualified from being a charity trustee or trustee for a charity in the following cases \u2013 [\u2026] Case K P is subject to the notification requirements of Part 2 of the Sexual Offences Act 2003 [\u2026] (3) While a person is disqualified under this section in relation to a charity, the person is also disqualified from holding an office or employment in the charity with senior management functions. 12. S.181 of the 2011 Act (so far as relevant) provides: (1) This section applies where a person (\u201cP') is disqualified under section 178(1). (2) The Commission may, if P makes an application under this subsection, waive P's disqualification\u2014 (a) generally, or (b) in relation to a particular charity or a particular class of charities. (2A) A waiver under subsection (2)\u2014 (a) may relate to the whole of P's disqualification or only to disqualification under section 178(3); (b) in relation to disqualification under section 178(3) may relate to a particular office or employment or to any office or employment of a particular description. (3) If\u2014 (a) P is disqualified under Case D E or I and makes an application under subsection (2) 5 years or more after the date on which the disqualification took effect, and (b) the Commission is not prevented from granting the application by subsection (5), the Commission must grant the application unless satisfied that, because of any special circumstances, it should be refused. 13. The statutory regime under these provisions provides for an automatic disqualification with a discretionary waiver. There is no statutory test, save for the requirement in s.181(2) that an application be made, to determine how that discretion should be exercised. The Commission must make that determination on a case-by-case, fact sensitive basis being mindful of the statutory objectives in sections 14, 15 and 16 of the 2011 Act. 14. The Appellant\u2019s automatic disqualification is imposed by s.178 Case K of the 2011 Act and as such the presumption in favour of a grant of a waiver under s.181(3) of the 2011 Act does not arise in this case. 15. S.319 and Schedule 6 of the 2011 Act provide circumstances in which an appeal may be brought to the Tribunal against specified decisions, directions or order of the Commission and the powers of the Tribunal if an appeal is allowed. 16. Ss.319 (4) and (5) of the 2011 Act provide: 4) In determining such an appeal the Tribunal\u2014 (a) must consider afresh the decision, direction or order appealed against, and (b) may take into account evidence which was not available to the Commission. (5) The Tribunal may\u2014 (a) dismiss the appeal, or (b) if it allows the appeal, exercise any power specified in the corresponding entry in column 3 of Schedule 6. 17. Column 3 of Schedule 6 sets out the powers of the Tribunal if an appeal against a decision to refuse a waiver under s.181(2) is allowed as follows: Power to\u2014 (a) quash the decision and (if appropriate) remit the matter to the Commission; (b) substitute for the decision any other decision of a kind which could have been made by the Commission. 18. Accordingly, the role of the Tribunal in this appeal is to make a de novo decisionconsidering the evidence before it. When considering an appeal by re-hearing the Tribunal\u2019s approach is bound by the Court of Appeal\u2019s judgement in R (Hope and Glory Public House Limited) v City of Westminster Magistrates\u2019 Court [2011] EWCA Civ 31 as approved by the Supreme Court in\u00a0Hesham Ali (Iraq) v Secretary of State for the Home Department\u00a0[2016] UKSC 60 at paragraph 45. Accordingly, the Tribunal must stand in the shoes of the Commission and take a decision based on the evidence before it, giving appropriate weight to the Commission\u2019s decision as the body tasked by parliament with making such decisions. It follows that as the Tribunal is required to stand in the shoes of the Commission when reaching its decision it too must have due regard to the statutory objectives, functions and duties at sections 14, 15 and 16 of the 2011 Act. 19. The then Chamber President Judge McKenna provided further persuasive guidance regarding the jurisdiction of this Tribunal when making a de novo decision, in Graham Hipkiss v The Charity Commissioner for England and Wales (CA\/2017\/0014) at paragraph 21 where is it authoritatively stated that in these circumstances the Tribunal \u201cis not required to undertake a reasonableness review of the Charity Commission\u2019s decision-making. Any public law criticism of the Commission\u2019s conduct is thus avoided by the Tribunal taking a fresh decision\u201d. 20. This being only the second time the Tribunal has heard an appeal against the refusal of a grant of a waiver under s.181 of the 2011 Act there is limited case law and indeed there are no decisions by the Upper Tribunal or High Court that would bind our decision. The Commission have sought to draw our attention to the approach taken in Dr Alan Blacker v The Charity Commission for England and Wales [2022] UKFTT 178 (GRC) which was decided by the then Chamber President, Judge McKenna. The Appellant has disputed the relevance of that case to the present appeals and sought to distinguish their circumstances from that which were live in Blacker. The Appellant expressed concern that heavy reliance on Blacker could lead to an error of parity. 21. Whilst not binding and whilst it is acknowledged that the factual matrix of that appeal was markedly dissimilar to this one, Blacker provides useful guidance as to the assessment to be made by the Tribunal in reaching its decision. In particular the analogy at paragraphs 16 to 19 therein between the statutory regimes of the Courts when considering applications for permission to act as a Director under s.17 of the Company Directors Disqualification Act 1986 and the Tribunal\u2019s when considering an application for a grant of a waiver under s.181 of the 2011 Act. 22. At [18] of Blacker, Judge McKenna states: [\u2026]First, I note that the court has power to allow a disqualified person to act as a director subject to conditions, whereas this Tribunal has no power to impose conditions in relation to a waiver. Secondly, I note that there are discrete public policy issues relevant to the \u2018deterrent\u00a0and\u00a0protective factors\u2019 when considering charities rather than commercial entities. Thirdly, I note that a s.17 application is made in relation to a particular company\u00a0and\u00a0not companies in general, so it is more closely analogous to a specific waiver than a general waiver. Nevertheless, there is an important similarity between the two regimes in that the 2011 Act provision, like the 1986 Act, has no statutory criteria for the exercise of the waiver. Thus, both types of decision involve the exercise of discretion by the judicial decision-maker on a fact-sensitive basis. The conduct of a balancing exercise, in which the \u201cpros\u201d\u00a0and\u00a0\u201ccons\u201d of granting a waiver are transparently listed before a judgment is reached, is the practice of the courts\u00a0and\u00a0one which I endorse in the context of this Tribunal. I note here (because it is relevant to what follows) that disputed facts must be proven by the relevant party\u00a0and\u00a0to the relevant standard before they can be allocated to the \u201cpro\u201d or \u201ccon\u201d side of the scales\u00a0and\u00a0finally weighed into the balance by a judicial decision-maker. 23. Whilst not binding we find this highly persuasive guidance on the correct approach to be taken by the Tribunal when undertaking an exercise of discretion on appeal against a refusal of a waiver under s.181 of the 2011 Act. 24. Judge McKenna goes on at paragraph 22 to consider the burden of proof on the Appellant as the person seeking to disrupt the status quo and notes that this has been described in company directors\u2019 disqualification caselaw as a \u201c\u201cheavy burden\u201d because the starting point is one of the Appellant having been adjudged unfit\u201d. Statute has dictated the circumstances in which automatic disqualification is proscribed, it therefore stands to reason that proving the suitability of departure from that starting points lay with the person seeking it. This is further supported by Hipkiss in which it was stated: \u201cThe burden of proof in a de novo appeal rests with the Appellant as the party seeking to disturb the status quo. The standard of proof to be applied by the Tribunal in making findings of fact is the balance of probabilities.\u201d D. Pleadings 25. The Appellant\u2019s Notices of Appeal relied on grounds that the Commission had failed to adequately take account of the circumstances surrounding the commission of the offences for which he was convicted nor appreciated the role that his autism played in this regard. Further, the Commission had unreasonably criticised ELMO\u2019s recruitment process, had failed to take their views into account and had failed to address reputational risk in respect of ELMO and penal reform charities with regard to the work of those organisations. Finally, failing to grant a class waiver would potentially disrupt his career progression and deprive the sector of the skills and experience he has to offer. The Appellant invites the Tribunal to set aside the Commission\u2019s decisions. 26. The Commission\u2019s Response dated 24 October 2025 and filed after the Review Decision of 15 August 2025 resisted the appeal and maintained that the factors in favour of granting either waiver were outweighed by the associated risks. The Commission denied failing to take into account the circumstances surrounding the Appellant\u2019s conviction and the role played in the commission of the offences by the Appellant\u2019s autism. They submit that whilst they have considered the mitigation it is not their role to go behind the conviction and that the Appellant\u2019s disability does not lessen the seriousness of the disqualification reason. They also denied failing to take ELMO\u2019s views into account and state they are not satisfied the Appellant\u2019s importance to ELMO is such that they can be sure he is the best candidate without a fair and open recruitment. Further, whilst they acknowledge the support of ELMO\u2019s board of trustees they consider ELMO has failed to provide any evidence to suggest they have considered the risks of appointing the Appellant. Finally, they resist the submissions that failing to grant a general waiver will negatively impact the Appellant\u2019s career progression and deprive the sector of his skills and experience. They submit that charity is not about career prospects and the Appellant can benefit the sector as a volunteer or adviser. Overall, they submit the Appellant\u2019s ground of appeal do not justify the quashing\/ substitution of their decisions. 27. On 07 November 2025, the Appellant filed a Reply to the Commission\u2019s Response. The Appellant made further representations as to how the context surrounding his offending should have been considered by the Respondent and submits that more weight should have been attached to his good conduct, low level of culpability and low levels of risk as factors in favour of granting the waivers. That failing to give due regard to the impact of his disability on his offending behaviour was a breach of the Commissions duties under the Equality Act 2010. That ELMO\u2019s approach to recruitment was reasonable in the circumstances and in assessing risk the Commission relied on generalised assumptions as to the impact on public confidence and failed to consider sector specific reactions. Finally, that recognising charity as a career does service to the people who work in it and the Commission had failed to recognise the importance of representation of those with lived experience in the penal reform sector. 28. We also had the benefit of Skeleton Arguments provided by both Parties in advance of the hearing. E. Evidence 29. The Commission in consultation with the Appellant prepared the Hearing Bundle spanning 380 numbered pages. In addition to the pleadings, the Commission\u2019s Decisions and Review Decision, the Bundle includes the Appellant\u2019s waiver applications, the Commission\u2019s decision log in relation to each application, correspondence trails relating to the applications and the Commission\u2019s relevant policies. Further, the Bundle contains letters in support of the Appellant\u2019s application, the Court of Appeal Decision in relation to his conviction and witness statements, psychological reports and an extract from a probation report from the Appellant\u2019s criminal proceedings. 30. As above we heard evidence from the Appellant and three witnesses at the hearing; two witnesses for the Appellant and one for the Respondent. In her evidence, Ms Holt Eze, confirmed she was giving evidence on behalf of the entire board of trustees who were unanimous in their passionate support of the Appellant\u2019s applications. 31. Whilst it is our intention to only refer to the relevant facts and evidence necessary to explain our decision, the Parties can nevertheless be assured that we have considered and had due regard to all of the evidence in the Bundle and that provided at the Hearing. 32. The Appellant had not filed a witness statement for themselves as required by the Directions of the Tribunal dated 03 October 2025. We considered it fair and just, noting there was no objection from the Respondent, to permit the Appellant to make an oral statement as evidence in chief. The totality of oral evidence will not be rehearsed in this decision. F. Discussions 33. The disputes in these appeals do not arise from contested facts relating to the disqualification reason or other conduct of the Appellant. The Appellant has been open and provided full details of the circumstances leading to imposition of the disqualification reason to the Commission and the Tribunal. The disputes arise around the evaluation of risks were the application to be granted. To assist the Parties understanding of the decision reached, we have set out our findings from the evidence in relation to risks which must be considered when considering an exercise of discretion. 34. The Commission submitted that the risks in these appeals can be put into three categories: risk to ELMO and to the wider charity sector; risks to the Appellant taking into account his vulnerabilities; and risk to other vulnerable individuals. We consider this is a practical way to consider risks and adopt this approach below. Further there is a dispute between the parties as to the extent that the circumstances surrounding the offending behaviour and subsequent imposition of a disqualifying reason should be considered when considering exercising discretion. This plays a central theme throughout both Parties submissions and therefore we shall set out our considerations in this regard first. The weight to be attached to the circumstances surrounding the Appellant\u2019s conviction 35. The Appellant seeks to make his case exceptional. The Appellant put to the Commissioner that if a waiver in relation to circumstances falling under Case K could not be granted to him then the discretion was illusory and asked, \u201cif a waiver cannot be granted in this case when could it be\u201d? He described his previous offending as a \u201cparticular exceptional case\u201d and questioned whether the Commission had a blanket approach to waivers in circumstances concerning sexual offences. 36. It would not be appropriate for this Tribunal to hypothesise a set of circumstances or list of features, the presence of which would indicate that an application under Case K ought to be denied or granted. The Commission must determine each case carrying out a fact sensitive assessment. It is of note that the notification requirements under s.82 of the 2003 Act arise for a range of offences and define notification periods in reference to sentence imposed upon conviction; not all offending under the 2003 Act will result in an indefinite notification period. 37. The offences for which the Appellant was convicted are strict liability offences: the conduct in itself is sufficient to amount to an offence with no requirement for mens rea to be present. The Appellant submits that the commission and Tribunal should have regard to this as a mitigating factor. The strict liability nature of those offences flows from statute as the intention of parliament. This was considered in the Appellant\u2019s appeal to the Court of Appeal at paragraph 28: \u201cThat said, it is to be clearly understood that offending with regard to a child under the age of 13 does not depend upon the knowledge or belief of the particular defendant. Of course, if there is a lack of knowledge or belief as to the relevant age, that bears on the issue of culpability and thereby on the issue of sentence. But the whole point of this sentencing regime, as imposed by Parliament, is that people under the age of 13 are to be protected from themselves. Thus, whilst of course it is very much a point in the appellant's favour that he never sought to initiate the sexual conduct, he never sought to groom Y, he never sought so take advantage of someone who he knew was under the age of 13, the fact is having sexual relations with a child under the age of 13 has serious consequences as the sentencing regime imposed by Parliament and as further set out in the Sentencing Guideline confirms\u201d. 38. The simple fact that an offence is strict liability is not in itself one which reduces the seriousness of the offending, conversely in some instances offences are designated as such because the behaviour itself is of a sufficiently serious nature. When assessing the seriousness of an offence, as in the criminal courts, it is appropriate to consider factors relating to culpability and harm. 39. The Appellant also stated that the imposition of their disqualifying reason, namely indefinite notification requirements, is determined by an algorithm. This is inaccurate. The notifications requirements are set down in statute reflecting the intention of Parliament. The table contained at s.82 of the 2003 Act is irrefutable evidence that Parliament has adjudged offending behaviour of the nature of the Appellant\u2019s to be so serious as to warrant the imposition of indefinite notification requirements. That is a factor which must be taken into consideration when considering an exercise of discretion in this appeal. 40. Nevertheless, whilst neither the Commission nor the Tribunal should seek to go behind the conviction, we are satisfied that when considering an exercise of discretion under s.181 of the 2011 Act, both must have due regard to any mitigating factors in the overall assessment of risk. Although in our view none are present in this case, we consider the same would be applicable to any aggravating factors. 41. There are several mitigating features relating to the Appellant\u2019s offending as set out in the above excerpt from the Court of Appeal\u2019s decision. Further, prior to this offending behaviour, the Appellant was of good character, he cooperated fully with the police upon becoming aware that he had committed criminal offences, there is no evidence he has re-offended since and he has been assessed as a low risk of reoffending. Not least we must also have due regard to the role the Appellant\u2019s autism played in the offending behaviour. We have considered the reports of Dr Halari and Dr Saminathan which support the fact the Appellant\u2019s autism played a significant role in his offending behaviour. It is also clear from the sentence the Appellant received and the comments of the Court of Appeal that the Appellant\u2019s autism significantly reduced the Appellant\u2019s culpability. We are satisfied it should therefore be given appropriate weight in the assessment of risk. 42. Overall, there are a number of mitigating factors relating to the Appellant\u2019s offending behaviour which must be taken into account as part of the overall assessment of risk, but they are not the sole considerations and the presence of them in itself is not determinative of the outcome of that assessment. Risk to ELMO and wider charity sector 43. When standing in the shoes of the Commission and considering the exercise of its powers we must seek to further the statutory objectives and functions contained with the 2011 Act. The most relevant objective in our assessment of risk is the public confidence objective to \u201cincrease public trust and confidence in charities\u201d.Also of particular relevance is the general function of \u201cencouraging and facilitating the better administration of charities\u201d. We must consider the reputational risk to the ELMO as an individual charity and to the charity sector as a whole. 44. We accept the Appellant\u2019s submission that the assessment of risk must be contextualised in reference to the needs and aims of the relevant charities. Ms Holt Eze gave evidence that she considered the risk of not having people with lived experience on the board of trustees was the greater reputational risk. This was supported by Ms Coomber\u2019s evidence. We further accept that a lack of representation for those with lived experience may carry reputational risks for penal reform charities. However, within her evidence Ms Maguire also confirmed that based on their current objects, ELMO would not fall within the category of a penal reform charity. 45. It became apparent in oral evidence that ELMO has not meaningfully engaged with an assessment of risk to the charity including reputational risk. Their assessment of risk is not robust and was limited to a singular consideration regarding the risk of reoffending. This is not a criticism of ELMO. We accept they are a relatively small, young charity who have relied heavily on a recommendation from HLPR following which they received no guidance on the waiver process. ELMO\u2019s support of the application in the absence of a full assessment of risk, whilst well intentioned, evinces naivety. 46. Blacker was a case involving dishonesty. As above the factual matrix of the case is distinct from the facts of this appeal in a number of ways, including the disqualifying reason. It is however in our view indicative of the perhaps naive approach taken to consideration of reputational risk by ELMO that both of the Appellant\u2019s witnesses recoiled at the prospect of allowing Mr Blacker to act as Trustee, when his disqualification arose from an offence which amounts to providing incorrect information on a form, but consider there is no significant reputational risk in allowing a vulnerable individual with convictions for serious sexual offences to carry out that role. 47. We accept there are both reputational and funding risks to ELMO arising from a lack of lived experience on their Board of Trustees, but they have failed to evidence that those risks and the associated benefits outweigh the risks associated with appointing this particular Appellant. ELMO also failed to consider whether there would be any other suitable candidates who carry less reputational risk, such as persons whose notification requirements have expired or a person with convictions for less serious offences. We do not make any findings whether there are such individuals but make note that this was not considered by ELMO before offering the Appellant the position. The starting point is that Parliament has adjudged that the Appellant is disqualified from being a Trustee and we are not satisfied that ELMO or the Appellant have discharged their burden to the Commission and as such it stands. 48. In considering the risk to the wider charitable sector, we consider this is a greater risk than to that of ELMO as an individual charity. A class waiver is a blanket waiver covering all charities whose object place them within that criterion. The Commission as the specialist regulator is best placed to assess the risk to the wider charity sector and we must apply significant weight to their view. 49. The Appellant in assessing the risk to the charity sector relies on his personal experience of people\u2019s reactions when learning of his convictions, which he described as sympathetic, supportive and not like the reaction to some other sexual offending. Accepting this to be the case, this evidence is anecdotal and does not take account of other circumstances in which this information may be communicated to the public perhaps without a prior explanation of the mitigating circumstances. We find we must also consider the risk that the Appellant\u2019s victim may speak out. We accept that the reactions of those within the penal reform sector may differ from those of the public as a whole. We do not however find that the Appellant has discharged their burden to the Commission and conclude that we must accept the Commissions view that were the Appellant to be granted a class waiver there is a risk to the public trust and confidence in charities as a whole and to this particular charity. Risk to Appellant as a vulnerable individual 50. We must also consider the risks to the Appellant as a vulnerable individual. The reports of Dr Halari and Dr Saminathan set out some of the ways in which the Appellant is impacted by their autism. 51. We heard and read evidence supporting a significant reduction in culpability in relation to the Appellant\u2019s offending behaviour stemming from the Appellant\u2019s Autism. Whilst this is a mitigating factor in that regard, it also confirms the Appellant has vulnerabilities and there is a risk he could be susceptible to deception. Although the evidence indicates at several points that the Appellant has been able to function in a workplace or educational setting, as is supported by the evidence of the Appellant\u2019s performance at the HLPR and as a volunteer adviser to ELMO, Dr Halari\u2019s report at paragraph 9 states: Mr Brown does not have a good enough understanding of what constitutes appropriate and inappropriate relationships, functioning, he struggles to understand and respond to social cues and others\u2019 emotions and intentions. This suggests that he is socially and emotionally vulnerable and at risk of social and emotional exploitation 52. There are duties and responsibilities incumbent on Trustees and those carrying out roles with senior management responsibilities. Neither waiver application addresses the risks to the Appellant if granted. No consideration was given to how to protect the Appellant from being manipulated into similar or different offending or how to mitigate this. As above Ms Holt Eze confirmed ELMO had not considered this as part of their risk assessment. Significant weight was relied upon by the Appellant, ELMO and HLPR regarding the Appellant\u2019s disabilities to reduce culpability for his previous offending but no balancing considerations of how this might give rise to any future risk in a Senior or Trustee position and how this can be mitigated. We make no findings on the level of risk to the Appellant as a vulnerable individual nor how this could or would be managed. The Appellant has not however satisfied the Tribunal to the relevant standard that there is no risk nor that we should not take this potential risk into consideration when carrying out our balancing exercise. Risk to other vulnerable individuals 53. Notwithstanding the application of appropriate consideration for the mitigating circumstances surrounding the Appellant\u2019s previous offending, the fact remains that the Appellant has a conviction for sexual offences against a child. In light of the circumstances of the Appellant\u2019s previous offending, we find it is necessary to consider the risk posed by the Appellant to vulnerable individuals with or without intent. Whilst the Appellant has been assessed as low risk of reoffending, indeed the probation officer assessed the risk of reoffending ranging from 3% to 7%, it cannot be said that there is no risk. The Psychologist\u2019s reports have identified that the Appellant is at risk of being manipulated and struggles to understand appropriate relationships. Whilst this mitigates the previous offending and it may be that the Appellant has learned from that experience, there is still a small risk he could be manipulated in an unfamiliar situation to commit different offending. 54. The Appellant and Ms Holt Eze gave evidence that the work of ELMO is exclusively conducted in adult prisons. Ms Holt Eze submitted that trustees rarely go into the prison, although later in her evidence she accepted that the Appellant had visited the prison previously and whilst there had engaged with prisoners. She gave evidence that the service was defined by the prison and that it may involve prisoners who are also vulnerable, although she was clear that it is primarily the musicians working for the charity who interact with the prisoners. When asked if a risk assessment had been conducted by ELMO in this regard Ms Holt Eze confirmed that there was no risk assessment which considered the risk to other vulnerable individuals. 55. ELMO are in the process of attempting to amend their objects. However, as they currently stand, we find the remit of work they could chose to undertake could bring the Appellant into contact with children and additional vulnerable individuals. 56. When asked during her evidence whether the work of penal reform charities would encompass work with young offenders, Andrea Coomber initially suggested that this was not the case as that work would fall under youth justice. However, she then confirmed that the HLPR, one of the largest penal reform Charities in the UK, undertook work relating to young offenders and that the HLPR had conducted a risk assessment for the Appellant covering those aspects of their work. Ms Coomber suggested that this risk could be managed by restrictions or conditions on the waiver but a waiver granted under s.181 of the 2011 Act is absolute and neither the Commission nor the Tribunal have the power to impose conditions. We find that if the Appellant were to be granted a class waiver in respect of penal reform charities this could include charities working with young offenders. 57. We accept the Appellant has been assessed as a low risk of reoffending. Nevertheless, in light of the circumstances in which the Appellant\u2019s previous offending arose, the scope of work undertaken by penal reform charities and the lack of any meaningful assessment of risk put forward by the Appellant, we are not persuaded there is no risk to other vulnerable individuals. G. Conclusions 58. Whilst the background and factual context are the same for each of the waivers sought, the considerations differ and therefore we will necessarily conduct separate balancing exercises in relation to both waivers. Application for a specific waiver for ELMO 59. In conducting our balancing exercise we find the following factors support the case for granting a waiver, i.e. the pros. Firstly the views of the ELMO. It is indisputable from the evidence that ELMO\u2019s Board of Trustees strongly support the Appellant\u2019s waiver applications. The Appellant is clearly held in very high regard by ELMO and has undeniably provided valuable assistance to them since his introduction to the charity. 60. However, there are a number of points which detract from the strength of this point. Whilst ELMO was not required to carry out a formal recruitment process, the Trustees relied wholly on the recommendation of the HLPR and a single meeting with the Appellant before agreeing to recruit him. Ms Holt Eze accepted in evidence that they had not considered any other candidates or prepared a role specification. We heard also evidence that at the time the trustees agreed to invite the Appellant to become a Trustee, not all of them were aware of the full nature of the Appellant\u2019s offending behaviour. We find, as was accepted by Ms Holt Eze in her evidence, that the suitability of the Appellant to be a Trustee was decided without meaningful engagement with a full risk assessment. When asked if the Trustees had considered the headings of risk set out above, Ms Holt Eze stated in hindsight she wished the Trustees had sat down and looked at it that way. 61. Secondly, we accept that the Appellant holds a range of skills and experience which are of demonstrable value to the work that ELMO wishes to undertake in the future. We accept that not only does the Appellant have lived experience including experience of the justice system from the perspective of an individual with autism but other professional qualifications and contacts within the penal reform sector that are of use to the charity. ELMO are resolute in their attempts to recruit individuals with lived experience and stated that they want the Appellant to be the first such Trustee not the only one. We accept that it is valuable to any organisation to have a diverse range of views and experience on the board of any organisation. This point is however weakened by the fact the Appellant can and has been providing input and support to ELMO as a volunteer since their introduction and could continue to do so if the waiver were refused. Although the Appellant does not have voting powers as a volunteer, we are satisfied that the esteem with which ELMO holds the Appellant ensures that his contributions and perspective can be adequately reflected in that position. The necessity argument to have a person with a serious criminal conviction on the board of Trustees is further weakened by the current objectives of the charity and the fact they are not currently operating as a penal reform charity. 62. Thirdly the Appellant\u2019s conduct since the disqualifying reason arose. The Appellant has not gone on to reoffend and has established a career for himself at the HLPR, who speak highly of him and the work he does. The Appellant described his work within the charity sector as a vocation and we heard evidence of the valuable input he has given to both HLPR and ELMO. It is however of concern that the Appellant, whilst accepting responsibility for his previous offending, on occasions appears to minimise its seriousness. 63. We find the following facts weigh against the granting of a waiver i.e. the cons. Firstly the conduct that led to the automatic disqualification. The starting point is that the offences for which the Appellant was convicted are serious in nature. It is the intention of Parliament that those convicted and receiving sentences of more than 30 months imprisonment for those offences should be subject to indefinite notification and consequently disqualified under s.178 of the 2011 Act regardless of any mitigating circumstances. 64. Secondly the amount of time passed since the disqualifying reason arose. The offences themselves occurred in 2016, the Appellant was convicted in 2018, and his sentence was completed in 2022. Whilst it has been almost 10 years since the Appellant committed the offences, his period on licence finished less than four years ago. Within the context of indefinite notification requirements these are not particularly long periods of time. Indeed in accordance with Schedule 3A of the 2003 Act the Appellant will not be eligible to seek a review of the notification requirements until 2035. This point is weakened somewhat by the absence of reoffending or breaches of his notification requirements. 65. Thirdly damage to public trust and confidence in the charity. We have set out our considerations of risk in detail above. We place particular weight on the views of the Commission being mindful of their specialist knowledge of the sector. The Commission\u2019s view is that granting a waiver would be damaging. The Appellant has not satisfied us on the evidence provided that the risks identified could be suitably mitigated. The Appellant\u2019s submissions on the positive reception he has received when people learn of his previous offences is circumstantial and does not address the reputational risk to the sector as a whole. 66. Overall, having weighed all of the evidence before the Tribunal we find that the balance tips in favour of refusing a waiver. Whilst there are some not insubstantial factors in support of granting, they do not outweigh the significant factors in support of refusing a waiver. It follows that we must conclude that it is appropriate and proportionate to refuse the application for a specific waiver for ELMO. Application for a waiver for a class of charities 67. Save for the specific considerations relating to the views of ELMO and the importance of the Appellant to ELMO, we have included the same considerations as above in our balancing exercise for the application for a class waiver plus these additional points. 68. Firstly, we find an additional factor in favour of granting the application is the user perspective of penal reform charities. We accept that having individuals with lived experience is valuable and necessary to this class of charities to inspire confidence in their users. We are also satisfied that having individuals with lived experience as Trustee or senior positions within these charities can improve the service they deliver. This point is weakened as the Appellant is already in a position to inspire confidence in users by way of his employment and involvement as a volunteer in these organisations. Further it does not follow that the necessity to have people with lived experience in positions in these charities means there is a necessity for this particular Appellant to hold such a position. 69. We find the following an additional factor weighing against the granting of the waiver. Firstly, this application is for a class waiver rather than a specific charity. The scope of the work of penal reform charities is not clearly defined. If granted the Appellant could be appointed as trustee or to a senior position in any charity whose objects contain an element of penal reform, therefore the associated risks in granting are greater. 70. Finally, the Appellant submitted that the class waiver should be granted as he is keen to pursue a career in the charity sector. He submits he should be given the same opportunities to progress as his colleagues, however, Parliament by virtue of s.178 of the 2011 Act has decided that is not necessarily the case. We do not consider furtherance of the Appellant\u2019s career to be a relevant factor in our balancing exercise. 71. Whilst we accept that rehabilitation should be at the forefront of any penal reform activities, there are many ways in which offenders can be rehabilitated by being offered paid employment with the charities to provide help and guidance and advance their careers. Parliament has only intended to exercise caution for senior management and Trustee positions subject to waivers being granted in appropriate circumstances. Overall, having weighed all of the evidence before the Tribunal we do not find that the Appellant has discharged their burden of proof. Whilst there are some factors which mitigate risk, they do not outweigh the significant risk factors in support of refusing a waiver, that have failed to be addressed in any persuasive way by the Appellant, ELMO or HLPR. It follows that we must conclude that it is appropriate and proportionate to refuse the application for a waiver for a class of charities. 72. Finally, the Appellant submitted in their skeleton argument and at the hearing that the Commission\u2019s decision that the Appellant\u2019s autism did not lessen the seriousness of the disqualifying reason was a breach of their duties under the Equality Act 2010. This Tribunal\u2019s jurisdiction in this appeal is to make a de novo decision, not to conduct a reasonableness review of the Commission\u2019s decision making. As such we make no findings on this point. 73. Therefore, for the reasons given above we find that the Commission\u2019s decisions of 17 December 2024 and 15 August 2025 to refuse to grant a waiver to a particular charity and to a particular class of charities were correct and their decisions are upheld. 74. The Appellant\u2019s passion for the charity sector and the work undertaken by charities within the penal reform sector was abundantly evident throughout these proceedings. We express the hope that he will continue the clearly valuable work he provides to the sector both as an employee of HLPR and as a voluntary advisor to ELMO. The Appellant will be eligible to seek a review of the indefinite notification requirements in 2035. If the notification requirements are discharged at that time, all things being equal, he will cease to be disqualified under s.171 of the 2011 Act at that time. We end by stating that our decision is not indicative that there are no circumstances in which the Appellant would be granted a waiver. If the Appellant chooses to apply for further waivers in the future, he and the charitable organisations involved should take care to demonstrate a deep engagement with and robust assessment of risk. Signed: Judge ArnellDate: 23 March 2026<\/p>\n<\/div>\n

\n

Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

A. Background 1. On 20 September 2018, the Appellant pleaded guilty to three counts of rape of a child under 13, one count of attempted rape of a child under 13 and one count of sexual assault of a child under 13. On 31 October 2018 he was sentenced to a period of imprisonment of four years. Consequently, the Appellant…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[8234],"kji_chamber":[],"kji_year":[7610],"kji_subject":[7612],"kji_keyword":[7633,7693,7715,7622,8235],"kji_language":[7611],"class_list":["post-561720","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-first-tier-tribunal-general-regulatory-chamber-charity","kji_year-7610","kji_subject-fiscal","kji_keyword-appellant","kji_keyword-charity","kji_keyword-commission","kji_keyword-evidence","kji_keyword-waiver","kji_language-anglais"],"yoast_head":"\nLee Gary Brown v The Charity Commission for England and Wales - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/lee-gary-brown-v-the-charity-commission-for-england-and-wales\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Lee Gary Brown v The Charity Commission for England and Wales\" \/>\n<meta property=\"og:description\" content=\"A. 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