CONTRACTING AUTHORITIES

February 26th, 2025 by James Goudie KC in Decision making and Contracts

On 24 February 2025 the Cabinet Office has issued GUIDANCE on the role of the Procurement Review Unit (PRU).  The PRU will have responsibility for “oversight” of the new regime under the Procurement Act 2023. Its initial aim will be to ensure that the changes introduced by the Act are “embedded within contracting authorities”. The PRU will investigate (1) contracting authorities, to ensure compliance with  the Act and (2) suppliers, for possible addition to the Debarment List.  Private utilities and some NHS personal care services are, however, out of scope of the PRU. The Guidance states that the PRU is designed to deliver the following benefits:-

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ECHR ARTICLE 4

February 25th, 2025 by James Goudie KC in Human Rights and Public Sector Equality Duty

In R ( RWU ) v ACADEMY GB (2025 ) EWCA Civ 147 it is held that the trigger or threshold test for identifying a case of  potential CHILD CRIMINAL EXPLOITATION is whether the state authorities were aware or ought to have been aware of circumstances giving rise to a credible suspicion that the child concerned had been trafficked or exploited or that there was a real and immediate risk of their being trafficked.

 

JURISDICTION

February 24th, 2025 by James Goudie KC in Judicial Control, Liability and Litigation

In IRWIN MITCHELL TRUST CORP LTD v KS ( 2025 ) EWCOP 7 (T2) the Court of protection considered as a preliminary issue whether it retained jurisdiction over the property and affairs of a young person aged 14 ( who lacked capacity and would continue to do so ) after her CHANGE OF HABITUAL RESIDENCE from England and Wales to India. Before that jurisdiction derived from the Mental Capacity Act 2005. The Court retained jurisdiction. The retention of jurisdiction following the change was consistent with the aim of HAGUE CONVENTION 34 on Jurisdiction etc. There was no gap in protection.

 

COMMUNITY INFRASTRUCTURE LEVY

February 24th, 2025 by James Goudie KC in Planning and Environmental

CAPTAIN LEE JONES v SHROPSHIRE COUNCIL (2025) EWHC 365 (Admin) is an application for Judicial Review of the Council’s Decision to issue and serve on the Claimant a CIL Stop Notice under Regulation 90 of the Community Infrastructure Regulations 2010. Read more »

 

RATES RETENTION

February 24th, 2025 by James Goudie KC in Council Tax and Rates

The Non-Domestic Rates ( Designated Areas ) Regulations 2025, S.I. 2025/180, form part of the rates retention system. They allow local authorities to retain 100% rather than 50% of growth in business rates income in specified areas. They designate 6 areas, primarily in the East Midlands and the North East.

 

GUIDANCE

February 24th, 2025 by James Goudie KC in Decision making and Contracts

A Welsh Government publication provides Guidance on Frameworks under the PROCUREMENT ACT 2023, both framework agreements and the new “ open frameworks “, and on call-off contracts.

 

PLANNING APPLICATION

February 21st, 2025 by James Goudie KC in Planning and Environmental

Section 70C of the Town and Country Planning Act 1990 bears the heading “power to decline to determine retrospective application”.  Its purpose, or one of its purposes, is to prevent repeat planning applications being used to delay or frustrate ENFORCEMENT ACTION by taking many “bites of the cherry”.  In R (MORAN) v MEDWAY COUNCIL (2025) EWHC 350 (Admin) the Council invoked Section 70C in the decision challenged declining to determine a planning application submitted by the Claimant. A LPA can do that under Section 70C(1) Read more »

 

MERGER

February 21st, 2025 by James Goudie KC in Judicial Control, Liability and Litigation

The appeal in NASIR v ZAVARCO plc (2025) UKSC 5 concerned the scope of the longstanding English law doctrine of merger. In short, the question is whether the doctrine, by which a cause of action merges with a judgment in the action, applies to a declaratory judgment. The Supreme Court held that it does not.

The doctrine of merger was developed as a means to promote finality in litigation and to prevent duplicative and vexatious litigation. Unlike the standard defence of res judicata in the form of cause of action estoppel, which prevents the contradiction of an earlier judgment as to the existence or non-existence of a cause of action, merger was designed to make a litigant seek his or her remedies in one action by extinguishing a cause of action when judgment has been given on it. Read more »

 

ANTI-SOCIAL BEHAVIOUR

February 19th, 2025 by James Goudie KC in Local Authority Powers

TROWER v ELMBRIDGE BOROUGH COUNCIL ( 2025 ) EWHC 314 ( Admin ) concerns a challenge to a PUBLIC SPACES PROTECTION ORDER under the ANTI-SOCIAL BEHAVIOUR etc ACT 2014 restricting the unauthorised mooring of riverboats in certain areas.  It had been reasonable for the authority to conclude that littering and noise from boat users was anti-social behaviour and to associate the behaviour with unauthorised mooring. It was a legitimate factor that boats in neighbouring areas might be displaced into the authority’s area.

 

CHILDREN IN NEED

February 19th, 2025 by James Goudie KC in Social Care

Local authorities are required to deliver necessary support to a child in need under the Children Act 1989. In WEST SUSSEX COUNTY COUNCIL v AB ( 2025 ) EWCA Civ 132the Court of Appeal says that a court order should not be used solely to encourage an authority to do that which it is already statutorily obliged to do. Once a full care order is made the Court would not have jurisdiction to review the operation of a care plan or require the authority to adhere to the key elements of any care plan; and the authority could amend or fundamentally alter a Court approved care plan.