COB v Disclosure and Barring Service (Safeguarding Vulnerable Groups) [2026] UKUT 188 (AAC) (09 May 2026)

Executive summary

The Upper Tribunal heard COB’s appeal against DBS decisions to place her on both the children’s and adults’ barred lists under the Safeguarding Vulnerable Groups Act 2006. It held DBS had made no mistake of law or fact and confirmed the barring decision, concluding that the 2022 incidents alone justified inclusion and that the 2004 incident did not need to be relied on.

Key points

• Parties: COB appealed against the Disclosure and Barring Service (DBS).
• Holding: the Tribunal confirmed DBS’s decision to include COB in both barred lists.
• Reasoning: it found no mistake of fact in DBS’s findings on the 2022 incidents and held barring on that basis was proportionate.
• Reasoning: it did not need to determine alleged factual mistakes about the 2004 incident because that incident was not necessary to the outcome.
• Legal frame: the appeal was governed by section 4 and Schedule 3 of the Safeguarding Vulnerable Groups Act 2006, with the Tribunal limited to law/fact errors.
• Sanctions/export-control angle: no direct sanctions or export-control issues appear in the text; the only enforcement consequence discussed is contempt for breaching the anonymity order.

Why it matters

This is a safeguarding and public-protection ruling, not a sanctions or export-control decision. Its relevance for geopolitical or sovereign-risk work is indirect: it shows how UK administrative tribunals apply preventive exclusion powers where vulnerable-person risk is found, and how strictly appeal grounds are confined.

Implications

For compliance and litigation strategy, the case reinforces that DBS barring appeals turn on demonstrable errors of law or fact, not a general merits review of whether inclusion is ‘appropriate.’ It also shows the Tribunal may disregard older allegations if later findings alone support barring, and that anonymity orders in sensitive proceedings carry contempt exposure.