“… Special circumstances are either: · uncommon or exceptional, or · where the strict application of the penalty law produces a result that is contrary to the clear compliance intention of that penalty law.” 55. HMRC’s manuals reflect their view as to the meaning of the term special circumstances, but they do no more than that. They do not really assist us in ascertaining how the term should be construed. There is no authority as to the meaning of the term in the context of Schedule 56. However there was no real dispute between the parties as to what it meant. 56. In Clarks of Hove Ltd v Bakers’ Union[1979] All ER 152 the House of Lords considered the meaning of “special circumstances” in the context of employment law. Geoffrey Lane LJ said that “… to be special the event must be something out of the ordinary, something uncommon …”