Wheeler v Leicester City Council [1985] AC 1054

Facts

  • Leicester City Council exercised its powers under the Race Relations Act 1976 to penalize the Leicester Rugby Football Club.
  • The council acted because some club players joined a rugby tour in South Africa during the apartheid era.
  • The council controlled the club’s access to certain recreational grounds and limited its use based on the club’s decision not to prevent its players from participating in the tour.
  • The council cited the promotion of good race relations as justification for its actions.

Issues

  1. Whether the council’s use of statutory powers under the Race Relations Act 1976, to penalize the club for not preventing its members from touring South Africa, was lawful.
  2. Whether the council acted for an improper purpose—reasons outside the intention of the Race Relations Act.
  3. Whether penalizing the club for acts it was not legally required to perform constituted unreasonable or unlawful administrative action.

Decision

  • The House of Lords held that the council’s actions were unlawful.
  • The Lords determined that, although the stated goal was promoting good race relations, the genuine reason was to penalize the club for not conforming to the council's stance on the South Africa tour.
  • This misuse of powers for an outside purpose rendered the council’s actions invalid.
  • Lord Templeman emphasized that statutory powers must only be exercised in alignment with the intention of the statute.

Legal Principles

  • A public body must exercise powers only for the statutory purposes for which they were granted.
  • Actions taken for reasons unrelated to a statute’s intention are unlawful, even if they fall within the statute’s literal terms.
  • The case affirms the principle of “proper purpose” in administrative law.
  • The judgment is consistent with the Wednesbury unreasonableness doctrine—that decisions based on irrelevant considerations or for improper purposes may be quashed.

Conclusion

The House of Lords’ ruling in Wheeler v Leicester City Council established that public bodies act unlawfully if they use statutory powers for purposes which the legislature did not intend, reinforcing limitations on administrative discretion and safeguarding fair governance.

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