IRC v Federation of Small Businesses (1982)

Court: House of Lords

Facts: The Federation of Small Businesses sought judicial review regarding the Inland Revenue's investigation into casual newspaper workers who were allegedly signing off with fake names for tax purposes. The Federation challenged the handling of this matter, arguing that the Inland Revenue's actions were improper.

Issue: Whether the Federation of Small Businesses had standing to bring a judicial review action against the Inland Revenue.

Held: The House of Lords held that the Federation did not have standing to pursue the judicial review because they lacked sufficient interest in the matter. Their claim was rejected on the grounds that their connection to the issues at hand was not direct enough to confer standing.

Key Judicial Statements: Lord Fraser stated: “Interestingly, however, they added that the Federation would have had standing had the Inland Revenue committed some exceptionally grave or widespread illegality” [647]. The reasoning clarified that standing was not determined by the closeness of their connection as taxpayers, but rather the nature of the alleged illegality.

💡LevelupLaw: This case underscores the principles surrounding standing in judicial review, emphasizing that a party must demonstrate sufficient interest in the matter at hand. It also highlights the potential for standing in cases involving severe or widespread illegality, suggesting a broader interpretation under specific circumstances