Associated Provincial Picture Houses v Wednesbury Corp [1948] 1 KB 223

Court: Court of Appeal

Facts: Wednesbury Corporation imposed conditions on the opening hours of cinemas, specifically prohibiting unaccompanied children from attending on Sundays, based on the belief that children should be in church. Associated Provincial Picture Houses challenged this decision in court, arguing that the council’s rule was unreasonable.

Issue: Was the decision made by Wednesbury Corporation to prohibit unaccompanied children from attending cinemas on Sundays a reasonable exercise of their powers?

Held: The court held that the council's decision was lawful but noted that public authorities must exercise their powers reasonably. However, the court concluded that it could not determine the reasonableness of the council’s decision itself, as this was a matter for the council’s discretion. The standard applied was whether a reasonable decision-maker could have reached the same conclusion.

Key Judicial Statements: The court distinguished between the concepts of reasonableness and illegality in administrative law, asserting that while the council has the power to impose conditions, such power must be exercised within the bounds of reasonableness. The decision highlighted that courts should not intervene unless the decision was "so unreasonable that no reasonable authority could ever have come to it."

💡LevelupLaw: established the Wednesbury test, which requires that public authorities' decisions must be reasonable and within the limits of their powers. It emphasizes the court's role in reviewing administrative decisions while respecting the discretion afforded to public bodies.