Abstract
This article describes the recent decision of the European Court of Human Rights in the case of a patient with personality disorder detained under a restriction order in Scotland's high security hospital. This is set in the context of recent case law in Scotland in similar cases and in England where forensic patients have made challenges, in domestic courts under the European Convention on Human Rights (ECHR), to their detention and treatment. We conclude that the ECHR has offered little in the way of tangible benefit to such patients.
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