Tomlinson v Birmingham City Council [2003] UKHL 47

House of Lords

Facts: Tomlinson challenged the application of Article 6 in the context of public benefits and services. The issue was whether these awards or benefits fell under 'civil rights' and thus required Article 6 compliance.

Held: Lord Hope clarified that awards of services or benefits do not constitute 'civil rights' under Article 6. Consequently, Article 6 does not apply to such administrative decisions. The Court preferred clarity over the 'elasticity' of the concept of 'full jurisdiction.'

Judicial Statement: Lord Hope remarked, “The application of Article 6 to administrative decisions involving benefits should be limited, focusing on clarity rather than an imprecise test of 'full jurisdiction.'”