## Facts

- JS, a disabled individual, received housing benefit which was reduced due to the presence of non-dependent adults in his home under regulations known as the “spare room subsidy.”
- JS argued that the regulations disproportionately impacted disabled individuals who require larger accommodations, constituting discrimination under Article 14 and Article 1 of Protocol 1 of the European Convention on Human Rights (ECHR).
- The legal challenge focused on whether the housing benefit reduction was justified and proportionate in light of its significant effect on the rights of disabled persons.

## Issues

1. Whether the social security regulations reducing JS’s housing benefit pursued a legitimate aim.
2. Whether the measures adopted to achieve that aim were proportionate, given their impact on disabled individuals under Article 14 and Article 1 of Protocol 1 ECHR.
3. Whether cost-saving considerations could justify measures that had disproportionate effects on vulnerable populations.

## Decision

- The Supreme Court recognized the government’s aim of reducing expenditure and promoting efficient use of social housing as legitimate.
- Applying a four-stage proportionality test, the Court found the impact on disabled individuals requiring larger or modified accommodation was not justified by the expected savings.
- The Court held that the regulations, as applied to JS, were disproportionate and thus incompatible with the requirements of the ECHR.
- The decision established that while financial objectives are relevant in policymaking, they do not automatically override the rights of vulnerable groups.

## Legal Principles

- Proportionality in administrative law requires that measures interfering with fundamental rights must:
  - Pursue a sufficiently important objective.
  - Be rationally connected to that objective.
  - Be the least restrictive means available.
  - Strike a fair balance between individual rights and community interests.
- The test for proportionality applied by the Court was articulated in four stages and drawn from European and domestic precedents, notably _Bank Mellat v HM Treasury (No. 2)_ [2013] UKSC 39.
- Cost considerations alone cannot justify measures that unduly burden vulnerable individuals or produce unjustified discrimination.

## Conclusion

The judgment in R (JS) v Secretary of State for Work and Pensions [2015] UKSC 16 significantly advanced UK administrative law, confirming that social security measures must be assessed through a rigorous, structured proportionality analysis, with special regard for the rights and needs of vulnerable groups such as disabled persons.
