Save Britain’s Heritage v Number 1 Poultry Ltd and Others [1991] 1 WLR 153
The point in plain English: Planning reasons are judged in their real context. A defect will not justify quashing a decision unless it leaves the challenger substantially prejudiced, for example by creating real doubt about whether the decision was lawfully reached.
What the House of Lords decided
The Secretary of State had granted planning permission and heritage consents for a major City of London redevelopment involving the demolition of listed buildings. Save Britain’s Heritage challenged the adequacy of the reasons.
The House of Lords restored the decision. Lord Bridge explained that the adequacy of reasons is not judged against an abstract ideal. The court asks whether any deficiency caused substantial prejudice, taking account of the issues that actually had to be decided.
How the case fits with later authority
Save Britain’s Heritage remains an important foundation for the modern reasons cases. The later House of Lords decision in South Bucks v Porter gives the familiar modern summary of the test.
For the practical Planning Geek treatment, see planning officer reports and reasons and our guide to listed buildings.
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