## Facts

- The Puhlhofer family sought housing assistance from Hillingdon London Borough Council, residing in temporary accommodation they claimed was unsuitable.
- The Council refused to provide permanent housing, determining the family was not "homeless" under the Housing (Homeless Persons) Act 1977, as they had accommodation, albeit temporary and substandard.
- The Puhlhofer family challenged the Council’s assessment, arguing they met the statutory definition of homeless and the refusal was incorrect.

## Issues

1. Whether the Council’s decision that the Puhlhofer family was not homeless was legally reasonable, given their temporary and substandard accommodation.
2. Whether courts can review and overturn a public authority’s factual findings in the context of judicial review.
3. Under what circumstances courts may intervene in public bodies’ decisions based on alleged factual errors.

## Decision

- The House of Lords upheld the Council’s decision, finding the interpretation of “homeless” to be legally reasonable.
- Lord Brightman, in the leading judgment, distinguished between legal and factual matters, holding that courts cannot overturn factual findings unless there is a total absence of evidence or the conclusion is plainly illogical.
- The Court stated that the quality or suitability of accommodation did not render the Council’s decision unlawful if some form of housing existed.
- The Lords emphasized that judicial review does not allow courts to substitute their own factual determinations for those of the public authority.

## Legal Principles

- Judicial review addresses only the lawfulness, not the correctness, of a public body’s decision.
- Courts generally defer to the factual judgments of decision-makers and will only intervene if the decision has no factual basis or is clearly illogical.
- The principle maintains separation of powers, restricting courts to assessing legality rather than re-evaluating facts.
- The Wednesbury unreasonableness test applies, requiring decisions to be unreasonable to the point of being irrational for intervention.
- Legal, procedural, or irrationality grounds (excluding mere factual disagreement) remain available for review.

## Conclusion

R v Hillingdon LBC, ex parte Puhlhofer [1986] AC 484 establishes that courts may only overturn factual findings in judicial review if there is a lack of evidence or clear illogic, marking a key boundary between legality and factual assessment in administrative law.

R v Hillingdon LBC, ex parte Puhlhofer [1986] AC 484 (HL)