Hi Rob
I haven’t researched it, but could you ask the DOH to refer the NR to the FTT given she wasn’t advised about her legal rights and is a lay person.
From a managers decision perspective, I guess you will need to serve them with a letter before claim for JR and see if they will hear it again with the NR being represented.
From the decision itself, the issues in SR all related to very serious issues of harm to her that were real and immediate. The grounds used in this decision are definitely not in that category. It is interesting to note the final reason isn’t a reason but is a direction to reconvene in 8 weeks, presumably if P remains detained at that point. I think this means the decision is not final and you can ask that a further hearing is listed asap and then argue the dangerousness criteria, that way avoiding the LBC being needed.
If the HM can just override the dangerousness criteria in the way they have done, then there is no point in the criteria existing at all.
Hope this helps.