was
subsequently transferred to US custody pursuant to a Memorandum of Understanding
(MoU) between the UK and the US.3 The Court held unanimously that there was
1
Rahmatullah v Secretary of State for Foreign Affairs and Secretary of State for Defence
[2012] 3 WLR 1087 (SC(E)) (‘Rahmatullah’).
2
At the time of writing Mr Ramatullah remains in US detention.
3
Rahmatullah (n 1) para 3. The MoU is entitled, ‘An Arrangement for the Transfer of
Prisoners of War, Civilian Internees, and Civilian Detainees…
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