## Facts

- The Agricultural Marketing Act 1958 created a milk marketing scheme with a committee to review complaints.
- Mr. Padfield, a milk producer in the South-Eastern region, challenged the disparity in milk prices compared to other regions.
- He requested the Minister of Agriculture to refer his complaint to the committee; the Minister refused, citing potential negative political consequences if the committee supported the complaint.
- The Minister's refusal led Mr. Padfield to initiate legal proceedings.

## Issues

1. Whether the Minister’s refusal to refer the complaint to the committee, based on political considerations, was contrary to the purpose of the Agricultural Marketing Act 1958.
2. Whether a statutory power conferred with discretionary elements allows the authority to act for reasons outside the statutory purpose.
3. Whether courts can review and set aside decisions made for improper purposes, even where wide discretion exists.

## Decision

- The House of Lords held that the Minister’s refusal was unlawful.
- It was determined that the Minister, although granted discretion, was required to exercise it in line with the statutory objectives.
- Rejection of the request on political grounds amounted to an improper purpose, frustrating the intent of the Act.
- Parliamentary intent was found to limit the exercise of discretion to furthering the Act’s aims.

## Legal Principles

- A statutory power, even with discretionary elements, must be exercised to achieve the purpose for which it was conferred.
- Decisions made for reasons extraneous to the legislation’s objectives constitute improper (bad) use and are subject to judicial review.
- Courts analyze the language, structure, and objective of the statute to determine the proper use of power.
- There is a distinction between 'bad use' (improper purpose) and the consideration of irrelevant or relevant factors; a decision can be legally flawed due to improper motivation, even if proper factors were considered.
- Later authority clarified the requirement to determine the primary purpose of the impugned decision.

## Conclusion

Padfield v Minister of Agriculture, Fisheries and Food [1968] AC 997 remains a leading authority in administrative law, confirming that discretionary powers must be exercised consistently with statutory objectives and that courts can intervene where power is used for an improper purpose, thus reinforcing the accountability of public decision-makers.

Padfield v Minister of Agriculture, Fisheries and Food [1968] AC 997 (HL)