Zhang, Application for Reconsideration by,

   This is an application by Zhang (the Applicant) for reconsideration of a decision of an oral hearing dated 4 April 2025 not to direct release and not to recommend a transfer to open conditions. The Applicant was formerly known by another name, but has changed his name by deed poll.

   Rule 28(1) of the Parole Board Rules 2019 (as amended by the Parole Board (Amendment) Rules 2024) (the Parole Board Rules) provides that applications for reconsideration may be made in eligible cases (as set out in rule 28(2)) either on the basis (a) that the decision contains an error of law, (b) that it is irrational and/or (c) that it is procedurally unfair. This is an eligible case, and the application was made in the extended time granted by the Board.

�          Representations on the Applicant's behalf dated 16 May 2025

�          The dossier, consisting of 1614 numbered pages ending with the DL

(a)          The Parole Board review has been protracted (starting in August 2021 and ending 3 years and 7 months later) to an extent which results in its being fundamentally flawed.