“Only the employment tribunal hears all the evidence first hand. The evidence available to the Employment Appeal Tribunal and to the Court of Appeal on an appeal on a question of law is always seriously and incurably incomplete. Much as one, or sometimes both, of the parties would like it to be so, an appeal from an employment tribunal is not a re-trial of the case. The scope of the appeal is limited to consideration of questions of law, which it is claimed arise on the conduct of the proceedings and the decision of the employment tribunal. The legal points must, of course, be considered in the context of the entirety of the proceedings and the whole of the decision, but with an awareness of the limitations on the court's competence to question the evidential basis for findings of fact by the employment tribunal. It is a rare event for the appellate body to have all the documents put in evidence in the employment tribunal. No official transcript of the oral evidence exists. If an order is made for production of the chairman's notes, it is usually on a selective basis, related to the particular grounds of appeal, which should always be particularised on a perversity challenge. Most important of all, none of the witnesses give oral evidence on an appeal.” 30. Those observations are equally pertinent in the present context of a special educational needs appeal, and so “First-tier Tribunal” and “Upper Tribunal” can be properly substituted for “employment tribunal” and “Employment Appeal Tribunal” respectively in the passage just cited. 31. There is, therefore, limited scope for challenging a First-tier Tribunal’s findings of fact on appeal to the Upper Tribunal on a point of law. On the basis of the Court of Appeal’s decision in R (Iran) v Secretary of State for the Home Department[2005] EWCA Civ 982 , such a challenge is sustainable in only four types of case. These are where the tribunal has (i) made perverse or irrational material findings of fact; (ii) failed to take into account and/or resolve conflicts of fact or opinion on material matters; (iii) given weight to immaterial factors; or (iv) made a mistake as to a material fact, which could be established by objective and uncontentious evidence, and which results in unfairness. Perversity or irrationality? 32. Mr Friel did not suggest that the tribunal’s findings were perverse or irrational, and rightly so in my view, not least given the high threshold which has to be met for such a challenge. However strongly they were contested, it cannot seriously be argued that this tribunal’s findings were so “wildly wrong” as to merit being set aside, as that test was framed by Sir John Donaldson MR in the Court of Appeal’s decision in Murrell v Secretary of State for Social Services (reported as Appendix to Social Security Commissioner’s decision R(I) 3/84). Failure to take into account and/ or resolve conflicts of fact or opinion on material matters? 33. Mr Friel’s principal challenge in this category was that the parents’ two witnesses, Mr D (an educational psychologist) and Ms W (a speech and language therapist), had both concluded that E needed what Mr Friel described as a ‘direct’ model of speech and language therapy, with a high level of permanent on-site specialist therapist input, as opposed to a ‘consultative model’, with specialist input delivered by outside specialists in periodic blocs and then delegated to Support Base staff, which Mr D and Ms W stated was insufficient to meet E’s needs. Mr Friel’s argument was that the tribunal had failed to address this issue and to resolve it one way or the other. 34. I do not accept this challenge. It is important to read the tribunal’s Decision and Statement of Reasons in the context of the case as a whole and in particular the Working Document. The tribunal made only very minor modifications to Part 3 of the Statement of Special Educational Needs. In doing so, the tribunal necessarily adopted and approved the contents of the Working Document as regards the required provision for speech and language therapy. Reading the two documents together, it is plain that the tribunal regarded the provision set out in Part 3 as sufficient and appropriate for E’s needs. As My Hyams put it, the tribunal considered the Part 3 issues and expressed itself “pithily but adequately”
“…This is an expert tribunal charged with administering a complex area of law in challenging circumstances. To paraphrase a view I have expressed about such expert tribunals in another context, the ordinary courts should approach appeals from them with an appropriate degree of caution; it is probable that in understanding and applying the law in their specialised field the tribunal will have got it right: see Cooke v Secretary of State for Social Security[2001] EWCA Civ 734 ,[2002] 3 All ER 279 , para 16. They and they alone are the judges of the facts. It is not enough that their decision on those facts may seem harsh to people who have not heard and read the evidence and arguments which they have heard and read. Their decisions should be respected unless it is quite clear that they have misdirected themselves in law. Appellate courts should not rush to find such misdirections simply because they might have reached a different conclusion on the facts or expressed themselves differently”
“The decision of a Tribunal is not required to be an elaborate, formalistic product of refined legal draftsmanship. It must contain an outline of the story which has given rise to the complaint, a summary of the Tribunal's basic factual conclusions, and a statement of the reasons which have led them to reach the conclusion which they do on those basic facts. The parties are entitled to be told why they have won or lost. There should be a sufficient account of the facts and of the reasoning to enable an appeal court to see whether any question of law arises. A Tribunal's reasons are not, however, intended to include a comprehensive and detailed analysis of the case, either in terms of fact or in law. Their purpose remains what it has always been, which is to tell the parties in broad terms why they lose or (as the case may be) win. These reasons should not be subjected to a detailed analysis. That is to misuse the purpose for which the reasons are given.”
“6. The legal test when determining the adequacy of reasons is not in doubt. It is fully discussed in the decision of the Court of Appeal in R (H) v. Mental Health Review Tribunal for North and East London Region[2001] EWCA Civ 415 ,[2002] QB 1 . Adopting what was said in English v. Emery Reimbold & Strick Limited[2002] EWCA Civ 605 ,[2002] 1 WLR 2409 , the essential requirement is that what the tribunal says should enable the parties and any appellate tribunal readily to analyse the reasoning that was essential to the decision. The tribunal should provide an explanation as to why it has accepted the evidence of one expert and rejected that of another. As these cases make clear, t he test is the same regardless of subject matter. Accordingly if tribunals are unsure about what is required when giving reasons they may find assistance from cases outside the specific area of law that they are dealing with.” 45. Notwithstanding Mr Friel’s obvious unhappiness with some aspects of the recent tribunal reform programme, which he conceded were essentially concerns of a political (with a small “p”) rather than legal nature, it seems to me that the approach in BB v South London & Maudsley NHS Trust and Ministry of Justice is entirely consistent with the pre-T-Day SENDIST authorities discussed above. 46. The second case on the adequacy of reasons (at least in part) was Hampshire County Council v JP[2009] UKUT 239 (AAC) , which concerned a tribunal’s decision on an appeal relating to a Statement of Special Educational Needs. A challenge by the local authority to the adequacy of the tribunal’s reasons was one of four grounds of appeal. As the three-judge panel explained, “where there is a crucial disagreement between experts and ‘the dispute involves something in the nature of an intellectual exchange, with reasons and analysis advanced on either side, the judge must enter into the issues canvassed before him and explain why he prefers one case over the other’ ( Flannery v Halifax Estate Agencies Limited[2001] 1 WLR 377 (CA))”