Secretary of State for Education and Science v Tameside MBC [1977] AC 1014

House of Lords

Facts: In the Tameside area, the local council decided to implement a comprehensive school system where all children would be admitted regardless of selection, unlike the previous grammar school system. The Secretary of State for Education and Science had seen and approved these plans but did not mandate their execution. When a new political administration took over, they modified the plans. The Secretary of State was concerned that these changes might lead to educational chaos and sought a mandamus to enforce the original plans. The new council appealed against this order.

Issue: Whether the Secretary of State’s decision, which was based on concerns about potential educational chaos, could be challenged in court.

Held: The House of Lords held that the Secretary of State had fundamentally misdirected himself. The new council’s proposed actions were not unreasonable, given that they agreed to implement the new scheme in a more phased manner.

Judicial Statement: Lord Wilberforce stated that while the Secretary of State's decision-making discretion could not be substituted by the court, the court could review whether the decision was made on the correct basis of facts and whether disruptions were deemed unreasonable. The Secretary of State’s concerns were found to be unfounded, as the new council's approach was deemed reasonable.