LPS Original · Live masterclass · Choose your date

The AGNI Judgment

The law as it now stands, applied in practice — from counsel in Cheshire West itself.

NEW 2026 Half-day Live online Scenario-led Overruled: Cheshire West

On 2 June 2026 the Supreme Court overruled Cheshire West — the case that has defined deprivation of liberty since 2014 — with no transition period. This course focuses on DoLS scenarios involving adults in hospitals and care homes. It is a practical half-day online session on the multifactorial test, worked examples, the borderline cases, valid consent, and how to approach the existing DoLS authorisations, Part 8 and requests. For BIAs, mental health assessors, AMHPs, DoLS teams and authorisers, MHA administrators and legal leads.

The test changed overnight. Your caseload didn’t.

Book a date For organisations
Delegate feedback · 243 responses

What delegates say.

From the live feedback polls at Neil’s recent AGNI and DoLS training — 243 delegates responded: an overwhelming 69% rated it “awesome!” and another 29% “very good”.

The most accessible way to understand the new ruling — really helpful and easy to follow.
Masterclass delegate · 21 July
Really informative training — the best I have attended. Will support me in my practice.
Masterclass delegate · 21 July
Excellent! Provides clarity on what I found to be a confusing judgement.
Masterclass delegate · 17 July
Do it! It will help you think about how to approach assessments, with useful practical examples.
Masterclass delegate · 17 July
A very thorough interpretation of the AGNI ruling. Consistent, reliable advice is required — and this is what you get from this training.
Masterclass delegate · 17 July
Everyone needs to do this course!! Really helpful and informative!
Masterclass delegate · 21 July
It’s a must do if you are working in the DoLS world.
Masterclass delegate · 17 July
I love the straight-talking approach and the way the information is presented — a complicated subject made enjoyable!
Masterclass delegate · 21 July
I would strongly advise everyone to attend — it challenges our thinking and will guide us going forward in our practice.
Masterclass delegate · 17 July
Get on it ASAP! Very helpful and the pace is very good.
Masterclass delegate · 17 July
A must for all BIAs and anybody working in adult social care and reviewing care.
Masterclass delegate · 21 July
Really good session with lots of useful information — everything was explained really clearly, which gave me much more clarity.
Masterclass delegate · 21 July
2 June 2026 judgment handed down 7–0 unanimous Supreme Court No grace period 364,900 applications in 2024–25 premised on the old test
One masterclass · Live online

Pick the date that suits.

The same half-day masterclass runs on multiple dates, live online — pick whichever suits you and your team. More dates are added as sessions fill.

LPS Members save 30% — subscribe at www.lpslaw.co.uk/members and get your own legal assistant as well

One booking. Thirty seats per course.

An organisation licence covers up to 30 staff to attend one of the courses — under £32 a head. Invoices and purchase orders welcome.

£950 +VAT Book for your organisation
The masterclass · Aims & objectives

What you’ll take away.

One aim: that you leave knowing what the Supreme Court decided in AGNI [2026] UKSC 16 — and how to apply it to the cases in front of you. The session takes no view on whether the decision is right or wrong; its job is to help you work with the law as it now stands.

By the end of the session you will be able to
  • Explain how the law arrived at AGNI — Bournewood, HL v UK, DoLS and Cheshire West — and why the Supreme Court unusually overturned its own precedent
  • Apply the multifactorial assessment that replaces the acid test: the intensity/degree of supervision and control, duration, the effect of the restrictions on the person, and how they are implemented
  • Recognise when valid consent might unusually be given to confinement, and the cautionary caveats around its use
  • Distinguish restriction from confinement in the borderline cases, using the judgment’s own worked examples
  • Approach the standing DoLS caseload defensibly — prioritising, reviews and renewals, and how only BIAs can make the Article 5 decision
  • Apply the new test in hospitals, including the interface with the Mental Health Act 1983 and Ferreira-type cases
  • Identify what AGNI left open — and where the test cases are likely to focus
  • Put it into practice through live scenarios in care homes, hospitals and supported living, polled and reasoned through as a group
New · Live online · One date

AGNI for Authorisers.

A half-day session for DoLS authorisers and signatories — scrutinising assessments and making authorisation decisions under the new test.

An online interactive half-day course on granting standard authorisations after AGNI [2026] UKSC 16 — what the multifactorial test means for those signing off DoLS decisions. Case studies throughout, with space for your own legal and practice issues.

Course content
  • The statutory safeguards after AGNI
  • Scrutinising the qualifying requirements — including BIA conclusions that there is no deprivation of liberty (Form 3A)
  • Not granting an authorisation: when, and how to record it (Form 6)
  • Conditions, recommendations and monitoring
  • Section 21A challenges and the Mental Health Act 1983 interface

By the end, participants will know what to look out for when scrutinising assessments, the legal pitfalls, supervisory bodies’ statutory responsibilities, and when and how to access the Court of Protection.

Coming this Summer role-specific e-learning

These are self-paced e-learning courses, not live sessions — there are no dates to book. Each one applies the new test to your setting, and because the live sessions aren’t recorded, this is the way to bring the AGNI training to your whole team. Two options for organisations: take licences on the LPS Law learning platform (£75 per person inc VAT · £950+VAT for up to 30 staff · LPS Members save 30%), or subscribe to embed the courses in your own LMS (pricing to be confirmed) — email training@lpslaw.co.uk.

Soon
Self-paced e-learning For DoLS teams & authorisers

Working through the standing caseload — triage, reviews, renewals and scrutiny — and what it means for supervisory bodies, DoLS leads and legal/quality teams.

Soon
Self-paced e-learning For BIAs & mental health assessors

Applying the multifactorial test in assessments, evidencing valid and tacit consent, and recording that stands up to scrutiny — for BIAs, assessors and AMHPs.

Soon
Self-paced e-learning For hospital staff

The hospital context — wards, A&E, the Ferreira line and the interface with the Mental Health Act — for ward staff, MHA administrators and acute trusts.

Soon
Self-paced e-learning For community & social care teams

Own homes, supported living and community settings, and the Court of Protection routes that apply — for social workers, community teams and commissioners.