Associated Provincial Picture Houses Ltd v. Wednesbury Corporation [1948]

[1948] 1 KB 223 · Court of Appeal · England & Wales

administrative lawadministrative law

Issue

When will a court quash an administrative decision on grounds of unreasonableness?

Held

The challenge failed because the condition did not meet the very high threshold for legal unreasonableness.

Exam use

Review the ratio and reasoning before applying this case in problem questions.

Summary

Canonical statement of irrationality review in common-law administrative law.

Facts

A local authority granted a Sunday cinema licence subject to a condition excluding children under fifteen, and the cinema operator challenged the condition as unreasonable.

Issue

When will a court quash an administrative decision on grounds of unreasonableness?

Held

The challenge failed because the condition did not meet the very high threshold for legal unreasonableness.

Ratio Decidendi

Wednesbury unreasonableness remains the classic high-threshold irrationality standard for judicial review, subject to later refinement in rights-sensitive contexts.

Reasoning

The Court of Appeal held that courts do not substitute their own view of the merits merely because they disagree with the decision. Intervention is reserved for decisions so unreasonable that no reasonable authority could have imposed them.

Essay-Ready Explanation Generator

Version 1 of 4

Reference to Associated Provincial Picture Houses Ltd v. Wednesbury Corporation ([1948] 1 KB 223) strengthens a administrative law answer because the case reflects the principle that Wednesbury unreasonableness remains the classic high-threshold irrationality standard for judicial review, subject to later refinement in rights-sensitive contexts. Applied to a problem question, the case should be used after identifying the issue as When will a court quash an administrative decision on grounds of unreasonableness? The stronger essay move is to connect the material facts to the court's holding, then explain whether the present facts support the same conclusion or justify distinguishing the authority.

Significance

Canonical statement of irrationality review in common-law administrative law.

Related Cases

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Exam Tips

Review the ratio and reasoning before applying this case in problem questions.

Revision Checklist

  • Name the issue before discussing facts so the marker sees the legal question immediately.
  • State the holding in one sentence, then use the ratio to explain why the court reached that result.
  • Use the citation and jurisdiction to show why this authority matters for the problem you are answering.
  • Pair this case with one supporting or contrasting authority if the question tests limits, policy, or exceptions.

Sources