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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