It is proportionate to a significant breach of the Code of Conduct to require the member in breach to undertake training in the meaning and application of the Code: Taylor v Honiton Town Council and East Devon District Council (2016) EWHC 3307 (Admin). Edis J also held that the duties of investigation of and decision upon allegations against members of the Town Council fell upon the District Council pursuant to the Localism Act 2011 and arrangements thereunder, including independent persons.