Complaint against the 2005 series of Dr Who

Introduction and Links to other pages

Request for extension to Appeal deadline

Following the rejection of the three complaints by the Editorial Complaints Unit, I was not clear how to appeal. The Information Unit and Editorial Complaints Unit each cited ratings and awards as a barrier to the complaints; their letters contained expressions such as "great success" and "huge hit".

The weakness in their responses was not being able to link the popular aspects of the show to the points about which the complaints were being made. I felt an extension to the deadline was necessary to enable me to think through how an appeal could be made, and so made the following request to the Governors' Programme Complaints Committee.

10 January 2006

Dear Sirs

I would like to appeal a complaint made unsuccessfully to the Editorial Complaints Unit. The ECU's final letter was dated 6 January 2006, reaching me on 9 January.

The purpose of this letter is to request an extension to the two month period normally allotted for appeals. There are three reasons for this request:

» My complaint is actually three complaints. These three complaints break down into individual points. Consequently, my appeal has to embrace a number of elements, rather than just one.

» My appeal is not straightforward and it will take a while to develop in my mind. I will then have to transfer the reasoning onto paper in a way that is understandable to others. This is a major task.

» While two months sounds lengthy, I am in full time employment and spend two or more hours commuting each day. The two months will pass quickly and I would be under pressure.

I make the additional point that the programme to which the complaint refers, Dr Who, is ongoing, so the complaint will remain relevant for some time to come.

I would therefore like to request an extension of a further two months, i.e. by the first week of May. This would greatly appreciated.

Yours faithfully, etc

Here is the GPCC's reply, dated 17 January 2006:

Evidently, the GPCC's definition of "everyone" includes everyone except the person making the complaint! This letter gave me quite a rattle. Whereas the ECU made at least a token effort to appear judicial, the GPCC's reply suggests that the appeal stage is nothing more than a rubberstamp. The following letter was sent to the GPCC's chairman, Mr Richard Tait:

21 January 2006

Dear Mr Tait

I am writing in connection to a letter from Ms Anna Lucas dated 17 January, responding to my letter of 10 January 2006. I understand that copies of these letters have been passed to you.

I wish to make the following protests regarding the response to my request for an extension:

1. The third paragraph states, "You have already been very clear and comprehensive about your complaint". The GPCC is not entitled to say this. The complaint to which Anna Lucas refers was addressed to the ECU and does not represent an appeal or communication to the GPCC. Any appeal is, by definition, a response to reasoning offered by the ECU. Until the appeal is submitted, the case for the complaint cannot be regarded as complete or whole; consequently, no-one at the GPCC can form an opinion of it. Therefore, to disallow my request on a view that my complaint is clear or comprehensive is incorrect.

2. Paragraph three says that all that I need do is submit a "summary of any additional points". This is not consistent with the GPCC's published remit which is to deal with appeals "rigorously and impartially". For this to happen, the GPCC must accord at least the same level of importance to the appeal as it does the original submission. This is because the original submission has been rejected by the ECU. To rely solely or mainly on the original submission is to effectively deny the right of appeal.

3. Paragraph three says that the GPCC is already in possession of the "full file". The file is not full until the GPCC has received the appeal.

4. Paragraph two says that it is in "…everybody's interests for the process to keep moving". It is not, however, in the interests of the appeal if the submission date creates problems for the person appealing. The ECU's submission period was more generous (three months, rather than two) and even that was a squeeze. All the GPCC needs to know is that if someone requests an extension, then it is for a reason. It does not matter whether the GPCC considers it a good reason or a bad reason; the point is that the reason exists and, as such, should be respected.

5. The appeals procedure need not prevent extensions; the operative word is "normally". This can be taken to permit flexibility in that, while there must be a declared date (otherwise, people might be submitting appeals twenty years later), this does not oblige the GPCC to refuse a later date of submission if specifically requested. I suggest that the main question that the GPCC might consider when considering a request for extension is whether the complainant can provide an alternative date on which the GPCC can rely. If so, certainty is maintained.

I am sure the GPCC agrees that, if an appeal is to be submitted, it should be done properly. That is not to say it need be voluminous, but the ECU's justifications for dismissing the original submission must be addressed carefully and fully; otherwise the appeal process has no value.

I would therefore like you to consider all these points in relation to my request for an extension.

Yours sincerely, etc

Mr Tait responded on 6 January 2006.
Richard Tait (source: bbc.co.uk)

I was disappointed that Mr Tait did not accept the principle that an appeal date could be extended, but decided to use the extra three weeks offered to request information from the Information Unit. Click here.