Section one Context detained or were to remain in detention and, if so, whether the detention should happen or continue.71 The new guidance was widely criticised for leading to ‘a worsening of protection for vulnerable people in detention’.72 Immigration lawyers and advocacy groups were concerned that the new policy limited the definition of torture to exclude non-state actors, increased the burden of evidence on vulnerable people and balanced vulnerability against a wider range of other factors. 71. Home Office, 2016, Immigration Act 2016: Guidance on adults at risk in immigration detention, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/547519/Adults_at_Risk_August_2016. pdf [accessed 09/11/17]. 72. The Guardian, 2016, ‘New immigration detention policy for ‘adults at risk’ needs urgent review’, https://www.theguardian.com/society/2016/sep/11/new-immigration-detention-policy-for-adults-at-risk-needs-urgentreview [accessed 13/11/17]. 27

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