I have written to the Lord Chancellor and Secretary of State for Justice today setting out my concerns about Government proposals to amend the existing statutory public sector Ombudsman arrangements through the Criminal Justice and Immigration Bill, by making provision for the establishment of Her Majesty's Commissioner for Offender Management and Prisons.

I am concerned that:

• The proposed new Commissioner would not be truly independent of those subject to investigation by the Ombudsman;
• The proposals would remove from the investigative reach of an existing independent Ombudsman large areas of state provision for some of the most vulnerable people in our society;
• The proposals would create further complexity in a system which is already overly complex and difficult for complainants to access.

As such, the proposals diminish rather than enhance the protection currently available for people in prison custody by way of access to an independent Ombudsman; and therefore make the Government vulnerable to potential criticism both within in the UK and beyond that, at best, it does not understand the concept of Ombudsmen; or, at worst, that it is intent on removing protection from some of the most vulnerable people in our society.

In view of these concerns I am circulating my letter and the accompanying paper widely to help inform those likely to be engaged in the debate.