Friday, May 17, 2013

Administrative Law -Lloyd v McMahon [1987] 1 AC 625

Lloyd v McMahon 

 

 

summary of the case

An auditor made a determination that councillors should reimburse Liverpool Council for a loss of over £100,000 caused by their misconduct (delay in setting a rate).  The councillors claimed the auditor’s failure to offer them an oral hearing made his determination a nullity.  The House of Lords held that an oral hearing was unnecessary.  Though the courts will readily imply into a statute additional procedural safeguards to secure fairness, what fairness requires depends on the character of the decision-making body, the kind of decision it has to make and the statutory or other framework (Lord Bridge).  Given that the councillors had not requested an oral hearing and had made full written representations to the auditor, which would not be supplemented in any material respects by an oral hearing, the auditor had not acted unlawfully in not affording an oral hearing.

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