R (D) v Parole Board [2019] QB 285

Court: Court of Appeal

Facts: D, a prisoner serving a life sentence for murder, applied for parole. The Parole Board conducted a review but denied D's application, citing concerns about the risk he posed to the public. D challenged the decision, arguing that the Parole Board's reasoning was irrational and that it failed to adequately consider the evidence presented in his favor. The case raised important issues regarding the standards for judicial review in the context of parole decisions and the balance between public safety and individual rights.

Issue: Was the Parole Board's decision to deny parole to D irrational, and did it properly consider the evidence presented?

Held: The appeal was allowed. The court held that while the threshold for proving irrationality is high, it is not insurmountable. The Parole Board's decision was found to lack a reasonable basis in the evidence provided. The court emphasized the need for decision-makers to properly evaluate and weigh the evidence before them, particularly in cases that significantly affect an individual's liberty.

Key Judicial Statements: The court acknowledged that "irrationality" is a stringent standard, stating, “The threshold for establishing irrationality is high; however, it is not an impossible barrier for claimants.” The judges further clarified that "a decision may be deemed irrational if it is not supported by any logical reasoning or if it disregards relevant evidence."

💡 Leveluplaw: illustrates the nuanced application of irrationality in judicial review, reinforcing that while public authorities must exercise discretion, they are still bound by the principles of rational decision-making and must adequately consider all relevant evidence.