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

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.