## Facts

- The case concerned the Secretary of State for the Environment’s decision to reduce the rate support grant allocated to Brent London Borough Council (LBC).
- Brent LBC argued that the Secretary of State acted unlawfully by pre-determining the outcome and failing to properly review the Council’s objections regarding the grant allocation.
- The rate support grant was a critical component of local authority funding, set according to a complex formula needing evaluation by the Secretary of State.
- The Secretary of State had publicly stated intentions to reduce local government spending, which Brent LBC claimed resulted in a rigid approach to setting their grant.

## Issues

1. Whether the Secretary of State had unlawfully predetermined the outcome by failing to consider Brent LBC’s case and objections to the grant reduction.
2. Whether a public authority can take a firm policy stance before final decisions, or must always be open to considering arguments and evidence.
3. Whether the Secretary of State’s process constituted a misuse of authority and was void as a result.

## Decision

- The Court of Appeal held that the Secretary of State’s decision was unlawful due to failure to properly consider Brent LBC’s objections.
- Lord Denning MR stated that a decision-maker may hold preliminary views, but must remain willing to reconsider in light of evidence and argument.
- The court concluded that the refusal to adequately engage with Brent LBC’s case rendered the process unfair and void.
- The Secretary of State’s entitlement to set policy did not override the duty to review the specifics of Brent LBC’s arguments.

## Legal Principles

- Administrative decision-makers must not have a closed mind and are obliged to consider objections and relevant evidence before reaching a conclusion.
- Even when public authorities have previously stated strong policy intentions, they cannot ignore arguments from those affected and must be open to persuasion.
- Fairness in decision-making requires legitimate consideration of all relevant matters; failure to do so is a misuse of authority.
- The case connects to the doctrine of legitimate expectations, requiring authorities to act fairly when changing policies on which parties have reasonably relied.
- The principle applies broadly to administrative actions by public bodies and has been reinforced in subsequent rulings such as R v Secretary of State for the Home Department, ex parte Khan [1984] 1 WLR 1337.

## Conclusion

R v Secretary of State for the Environment, ex parte Brent LBC [1982] QB 593 established that administrative decisions must not be predetermined and that affected parties' arguments must be fairly considered, affirming fairness as a central requirement of lawful public decision-making.

R v Secretary of State for the Environment, ex parte Brent London Borough Council [1982] QB 593