In Richards v Worcestershire County Council (2016) EWHC (Ch) the County Council and an NHS Commissioning Group failed to strike out a CPR Part 7 restitution are claim by an individual who alleged that they had been unjustly enriched as a result of their failure to provide services following their after-care assessment under Section 117 of the Mental Health Act 1983 and who had paid privately for such services. The claim did not have to be by judicial review. Clunis v Camden and Jones v Powys were distinguished.
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