Save Historic Newmarket Ltd & Ors v Forest Heath District Council & Ors

Save Historic Newmarket Ltd & Ors v Forest Heath District Council & Ors

The Core Strategy's environmental assessment failed to comply with EU Directive 2001/42/EC and the Environmental Assessment of Plans and Programmes Regulations 2004 because it did not properly identify, describe, or evaluate reasonable alternatives, nor did it provide reasons for their rejection. The final report did not sufficiently summarise or reference prior assessments, preventing consultees from understanding the rationale for the chosen strategy. This substantive breach requires relief regardless of prejudice. The procedural defect alleged regarding late technical documents did not cause prejudice to the claimants, as they had access and addressed them at the examination.

Parties
Claimant: Save Historic Newmarket Ltd; Claimant: Tattersalls Ltd; Claimant: Unex Group Holdings Ltd; Claimant: Jockey Club Estates Ltd; Claimant: Newmarket Trainers’ Federation; Claimant: Godolphin Management Company Limited; Claimant: Darley Stud Management Company Ltd; Defendant: Forest Heath District Council; Defendant: Secretary of State for Communities & Local Government; Interested Party: Edward Richard William Stanley, 19th Earl of Derby (Lord Derby)
Jurisdiction
England and Wales
Judgment Date
25 March 2011
Procedural Posture
Judicial Review / Judgment
Outcome
Claimants succeed on the first ground; relief to be determined after hearing counsel.
Legal Topics
Strategic Environmental Assessment, Procedural Compliance, Consultation Requirements, Local Development Framework, Core Strategy, EU Directive 2001/42/ec, Environmental Assessment of Plans and Programmes Regulations 2004

Case Brief

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Parties

Save Historic Newmarket Ltd

Claimant

Tattersalls Ltd

Claimant

Unex Group Holdings Ltd

Claimant

Jockey Club Estates Ltd

Claimant

Newmarket Trainers’ Federation

Claimant

Godolphin Management Company Limited

Claimant

Darley Stud Management Company Ltd

Claimant

Forest Heath District Council

Defendant

Secretary of State for Communities & Local Government

Defendant

Edward Richard William Stanley, 19th Earl of Derby (Lord Derby)

Interested Party

Procedural Posture

Judicial Review / Judgment

  1. 1 Whether the Core Strategy's environmental assessment complied with EU Directive 2001/42/EC and the Environmental Assessment of Plans and Programmes Regulations 2004
  2. 2 Whether procedural requirements regarding consultation and technical documents were breached

Ratio Decidendi

The Core Strategy's environmental assessment failed to comply with EU Directive 2001/42/EC and the Environmental Assessment of Plans and Programmes Regulations 2004 because it did not properly identify, describe, or evaluate reasonable alternatives, nor did it provide reasons for their rejection. The final report did not sufficiently summarise or reference prior assessments, preventing consultees from understanding the rationale for the chosen strategy. This substantive breach requires relief regardless of prejudice. The procedural defect alleged regarding late technical documents did not cause prejudice to the claimants, as they had access and addressed them at the examination.

Court Disposition

Claimants succeed on the first ground; relief to be determined after hearing counsel.