Tesco Stores Ltd v Secretary of State for the Environment [1...

Facts

• Tesco Stores Ltd sought planning permission for a development, engaging the statutory framework of the Town and Country Planning Act 1990.
• The Secretary of State for the Environment made a planning decision allegedly without properly considering all relevant factors and appropriately excluding irrelevant ones.
• The matter was brought before the House of Lords to clarify the requirements for decision-makers regarding the assessment and balancing of considerations in statutory decision-making, particularly in the context of planning permission.

Issues

1. Whether decision-makers must identify and consider all relevant statutory factors, and exclude irrelevant ones, when making administrative decisions.
2. How decision-makers should determine the scope of relevant considerations under the governing statutory framework.
3. Whether proper weight must be assigned to each relevant factor, with adequate reasoning and evidence.
4. The extent to which courts may review the sufficiency and rationality of the weighing of considerations in administrative decisions.

Decision

• The House of Lords held that decision-makers must consider all relevant considerations and exclude extraneous or irrelevant ones in accordance with statutory obligations.
• The scope of relevant considerations is governed by the legislative framework and must be determined through purposive statutory interpretation.
• It is not sufficient merely to identify relevant factors; they must also be weighed rationally and reasonably in reaching a decision.
• Decision-makers must base their conclusions on adequate evidence and provide clear, reasoned justification for the weight attributed to each factor.
• The requirement for a proper balancing exercise is fundamental; failure to do so may result in decisions being declared unlawful through judicial review.
• The case sets a precedent for structured, transparent, and fair administrative decision-making.

Legal Principles

• Decision-makers must consider all relevant factors prescribed or necessarily implied by statute and must not introduce irrelevant considerations.
• The weight assigned to relevant considerations is generally a matter for the decision-maker, but this must be reasoned and supported by evidence.
• Statutory interpretation guides which factors are considered relevant, requiring a purposive approach to legislative language and policy objectives.
• Exclusion of irrelevant consideration is essential; factoring in immaterial matters, such as biases or extraneous influences, can render decisions invalid.
• Judicial review serves to ensure accountability in the application of relevant considerations and adequacy of reasoning in administrative law.

Conclusion

Tesco Stores Ltd v Secretary of State for the Environment [1995] 1 WLR 759 established that administrative decisions must be based on the proper identification, weighing, and justification of all relevant factors within the statutory framework, while excluding irrelevant considerations. The case remains a significant authority for ensuring rational, fair, and accountable decision-making in administrative law.