R v Criminal Injuries Compensation Board, Ex parte A [1999] ...

Facts

• The claimant applied for compensation under the Criminal Injuries Compensation Scheme.
• The Criminal Injuries Compensation Board rejected the claim, concluding that the claimed injuries were not caused by the alleged crime.
• This decision was based on a misunderstanding of medical evidence, which the Board wrongly interpreted as conflicting with the claimant’s account.
• The House of Lords ruled that the Board’s error in evaluating the medical evidence constituted a major factual error, rendering the Board’s decision unlawful.

Issues

1. Whether judicial review could extend to decisions by public bodies founded on major non-jurisdictional factual errors.
2. Whether the Board’s misunderstanding of the medical evidence amounted to a sufficiently serious factual mistake to make the decision unlawful.
3. How to distinguish between “serious” factual errors that justify judicial intervention and minor mistakes that do not.

Decision

• The House of Lords held that judicial review is not confined to errors concerning jurisdictional facts; non-jurisdictional factual errors of sufficient seriousness can render a decision unlawful.
• The Board’s misinterpretation of the medical evidence was a significant factual error that directly affected the outcome, justifying the decision being set aside.
• The judgment clarified that for a factual error to invalidate a decision, it must be sufficiently serious—capable of affecting the outcome.

Legal Principles

• Judicial review may be based on illegality arising from significant factual mistakes, not limited to errors of law or jurisdiction.
• A factual error must be clear, material, and influential on the outcome to justify quashing a decision.
• The principle is distinct from Wednesbury unreasonableness; even a reasonable decision may be unlawful if based on a major factual error.
• Administrative fairness and accuracy are required in decisions impacting individual rights.

Conclusion

R v Criminal Injuries Compensation Board, Ex parte A [1999] 2 AC 330 established that substantial factual mistakes, even outside jurisdictional issues, can render administrative decisions unlawful. This ruling broadened the grounds for judicial review, reinforcing the need for accuracy and fairness in administrative decision-making.