Facts
- O, a disabled individual, challenged the London Borough of Hammersmith and Fulham’s decision to reduce her care package.
- The local authority, citing budgetary constraints, modified its eligibility criteria for social care services.
- As a result, O’s level of support was reduced despite her demonstrable ongoing needs.
- O argued that the decision was unlawful because it was Wednesbury unreasonable, failing to give proper consideration to her personal circumstances.
Issues
- Whether the local authority's reduction of O's care package, motivated by budgetary constraints, was so unreasonable as to satisfy the Wednesbury unreasonableness standard.
- Whether public bodies may rely on financial considerations to justify reductions to essential social welfare support notwithstanding individual needs.
Decision
- The Court of Appeal held that, while local authorities have discretion and may consider budgets, this discretion is not without limit.
- The reduction in O's care package was found to be Wednesbury unreasonable, as the authority failed to properly consider her individual needs and the specific impact on her welfare.
- The local authority's decision was quashed for being so unreasonable that no reasonable authority could have made it.
Legal Principles
- The Wednesbury unreasonableness test sets a high threshold: a decision is unlawful if it is so outrageous in defiance of logic or accepted moral standards that no sensible person could have reached it.
- Financial considerations cannot justify decisions that deprive individuals of essential support if they fail to meet minimum standards of reasonableness.
- Local authorities must conduct comprehensive and individualized assessments when determining social welfare entitlements; merely balancing budgets is insufficient.
Conclusion
The Court of Appeal in R (O) v Hammersmith and Fulham LBC clarified that Wednesbury unreasonableness applies to social welfare decisions: local authorities must consider individual needs even under financial constraints, and decisions that do not are susceptible to judicial review and being quashed for unreasonableness.