Court of Appeal quashes immediate custodial sentence after sentencing judge had suggested it might be suspended if defendant pleaded guilty
August 25, 2026
Jul 9, 2025 | By: Vicky Lankester
On 3 December 2020, a 15-year-old black schoolgirl was strip searched at her school in Hackney by three police officers. The intimate part of the search was carried out by two female officers. It was suspected that she was in possession of cannabis, although no drugs were ultimately found. The manner in which the child was searched was the subject of considerable publicity.
At a misconduct hearing concluding on 26 June 2025, a panel found a number of allegations proved, with two officers being found to have committed gross misconduct. They were dismissed without notice. A third officer was found to have committed misconduct and received a final written warning that will remain in place for two years.
The misconduct hearing concluded that the search of Child Q was unnecessary, inappropriate and disproportionate, and that it was humiliating and made her feel degraded. It was carried out without authorisation from a more senior officer, without an appropriate adult present and a proper record was not made afterwards, all in breach of training and police policy.
Of note, the panel did not find that any officer breached professional standards relating to equality and diversity, or honesty and integrity. It also did not find that race was a factor in the officers’ actions.
Strip searches are strictly controlled by Code of Practice C to the Police and Criminal Evidence Act 1984. In particular:
Strip searches on young people must be carried out with even more caution and care, due to their vulnerability. Breaches of the Police and Criminal Evidence Act 1984 or any of its Codes of Practice can result in any evidence obtained through such a breach to be ruled inadmissible in any subsequent criminal proceedings. It can also lead to civil action being taken against the police.
Since the incident with Child Q, there have been a number of reviews of practices and procedures regarding strip searches of juveniles and recommendations made.
A Safeguarding Review by the City & Hackney Safeguarding Children Partnership was carried out and published in March 2022. It concluded that:
The Metropolitan Police has also reviewed its procedures and policies regarding strip searches of children, which has been cemented in its Children’s Strategy. In particular, they have issued guidance to every officer on the frontline regarding the correct process and every strip search or more thorough search where intimate parts are exposed requires authorisation by a local officer of inspector rank.
As the Safeguarding Review concluded, the strip search of Child Q should never have happened and there was no reasonable justification for it. It is however interesting that it concluded that the school acted appropriately when concerns were initially raised about Child Q smelling of cannabis. It was once the police arrived that issues started to arise. The Safeguarding Review found that school staff should have done more to challenge to the police, seeking clarity about the actions they intended to take and were not focussed enough on Child Q’s safeguarding needs.
It would appear, therefore, that the issues lay with the police and the way they handled the strip search of Child Q. The officers did not comply with the requirements of Code C or police policy for dealing with such situations. Despite no findings being made relating to alleged breaches of equality, diversity, honesty and integrity, two of the officers were still found to have committed gross misconduct. This demonstrates the seriousness of the breach and the way in which Child Q was treated. This is in spite of there being admissions from the force that the training provided to officers surrounding strip searches of children was inadequate. Ultimately, it resulted in the officers losing their jobs.
This case highlights the importance of the Police and Criminal Evidence Act 1984 and its Codes of Practice being followed correctly, and the consequences that can flow if police officers do not comply with them. It also makes clear that police officers are individually accountable for complying with regulations and procedures, and cannot rely on the fact of poor and inadequate training.
Articles are intended as an introduction to the topic and do not constitute legal advice