R (Gilkes) v SSHD [1999] EWHC Admin 47

One of the two medical reports was too out-of-date to be reasonably relied upon for a s47 transfer to hospital; a transfer at the end of a prison sentence was not inherently unlawful; based on subsequent material from the same doctor, no relief would be granted as if the Secretary of State had insisted on an up-to-date report he would have made a transfer direction anyway.