Saravanamuthu v Secretary of State for Communities, Housing and Local Government & Anor [2025] EWHC 2132 (Admin) (12 August 2025)

Saravanamuthu v Secretary of State for Communities, Housing and Local Government & Anor [2025] EWHC 2132 (Admin) (12 August 2025)

The inspector did not breach his Tameside duty; he had sufficient evidence regarding funding and viability, including Cabinet reports, financial appraisals, and oral testimony. There was no legal requirement for independent scrutiny of costs. The inspector's reasons were adequate and addressed the key issues. The Dagenham decision was not a material comparator as the schemes differed in funding and context. The inspector lawfully concluded that compulsory purchase was necessary and proportionate, and alternatives were properly considered.

Citation
[2025] EWHC 2132 (Admin)
Parties
Claimant: Manoranjitham Saravanamuthu; First Defendant: Secretary of State for Communities, Housing and Local Government; Second Defendant: London Borough of Newham
Jurisdiction
England and Wales
Judgment Date
12 August 2025
Procedural Posture
Judicial Review (planning) / High Court Judgment on Application to Quash Compulsory Purchase Order
Outcome
Claim dismissed
Legal Topics
Compulsory Purchase Orders, Public Law, Judicial Review, Local Government Powers, Planning Permission, Human Rights, Proportionality, Duty of Inquiry, Adequacy of Reasons
Administrative Law Planning Law Compulsory Purchase Compulsory Purchase Orders Public Law Judicial Review Local Government Powers Planning Permission +4 more

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Parties

Manoranjitham Saravanamuthu

Claimant

Secretary of State for Communities, Housing and Local Government

First Defendant

London Borough of Newham

Second Defendant

Procedural Posture

Judicial Review (planning) / High Court Judgment on Application to Quash Compulsory Purchase Order

Legal Issues

  1. 1 Whether the inspector failed in his duty of reasonable inquiry regarding funding and viability of the scheme (Tameside duty)
  2. 2 Whether the inspector failed to give adequate reasons for his conclusions
  3. 3 Whether the inspector failed to have proper regard to a material consideration (the Dagenham decision)

Ratio Decidendi

The inspector did not breach his Tameside duty; he had sufficient evidence regarding funding and viability, including Cabinet reports, financial appraisals, and oral testimony. There was no legal requirement for independent scrutiny of costs. The inspector's reasons were adequate and addressed the key issues. The Dagenham decision was not a material comparator as the schemes differed in funding and context. The inspector lawfully concluded that compulsory purchase was necessary and proportionate, and alternatives were properly considered.

Court Disposition

Claim dismissed

Orders

  • The application to quash the compulsory purchase order is refused.
  • The compulsory purchase order remains operative.