Planning Min. v Herold [2014] 1 JLR 160 (23 January 2014)

Planning Min. v Herold [2014] 1 JLR 160 (23 January 2014)

The court held that there is no discretion to extend the 14-day statutory time limit for serving notice of third party appeal under the Planning and Building (Jersey) Law 2002, art. 114(7), unless the appeal involves the determination of a civil right for the purposes of ECHR art. 6. In such cases, the court may...

Source-derived case information.

Citation
[2014] 1 JLR 160
Parties
Applicant: Planning Minister; Respondent: Herold
Jurisdiction
Jersey
Judgment Date
23 January 2014
Procedural Posture
Appeal / Judgment
Outcome
appeal dismissed
Legal Topics
Time Limits for Appeal, Extension of Time, Third Party Appeals, Royal Court Rules 2004 R.1/5, Planning and Building (jersey) Law 2002 Art.114(7), ECHR Art.6
Planning Law Administrative Law Time Limits for Appeal Extension of Time Third Party Appeals Royal Court Rules 2004 R.1/5 Planning and Building (jersey) Law 2002 Art.114(7) ECHR Art.6

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Parties

Planning Minister

Applicant

Herold

Respondent

Procedural Posture

Appeal / Judgment

  1. 1 Whether the court has discretion to extend the 14-day time limit for serving notice of third party appeal under Planning and Building (Jersey) Law 2002, art. 114(7)
  2. 2 Whether Royal Court Rules 2004, r.1/5 or inherent jurisdiction allows extension
  3. 3 Whether ECHR art. 6 requires extension if civil rights are involved

Ratio Decidendi

The court held that there is no discretion to extend the 14-day statutory time limit for serving notice of third party appeal under the Planning and Building (Jersey) Law 2002, art. 114(7), unless the appeal involves the determination of a civil right for the purposes of ECHR art. 6. In such cases, the court may extend the time limit only if the very essence of the right of access to courts would otherwise be impaired, and only in exceptional circumstances where the appellant has acted promptly.

Court Disposition

appeal dismissed