“…the court will (subject to the overriding public interest) insist on such a requirement, and enforce such an obligation [to consult], where the decision maker’s proposed action would otherwise be so unfair as to amount to an abuse of power, by reason of the way in which it has conducted itself. In the paradigm case of procedural expectations it will generally be unfair and abusive for the decision-maker to break its express promise or established practice of notice or consultation. In such a case the decision–maker’s right and duty to formulate and re-formulate policy for itself and by its chosen procedures is not affronted, for it must have concluded that that interest is consistent with its proffered promise or practice. In other situations-the two kinds of legitimate expectation we are now considering-something no less concrete must be found. The cases demonstrate as much. What is fair or unfair is of course notoriously sensitive to factual nuance. In applying the discipline of authority, therefore, it is well to bear in mind the observation of Sir Thomas Bingham MR as he then was in ex parte Unilever at 690F, that “the categories of unfairness are not closed, and precedent should act as a guide and not a cage.” 19. In the paradigm case, a public authority may be found to have acted unfairly if a person liable to be affected by a change in an established policy or practice is not given an opportunity to make representations before the change is put into effect. However, it is clear that the doctrine of legitimate expectation can be invoked in other cases where it would not be fair to allow a public authority to depart from an established practice, even in a case where no duty to consult arises-see, for example, ex parte Unilever[1996] STC 681 , where the Inland Revenue’s refusal to accept late claims for tax relief after twenty years of accepting such claims was regarded by the Court of Appeal as “so outrageously unfair that it cannot be allowed to stand.” 20. We therefore agree with Mr Smale that a failure by the ISA to act in accordance with its own declared procedures may in some cases be unlawful.Section 4 of the Safeguarding Vulnerable Groups Act 2006 affords no right of appeal against the decision to place a person on a barred list, so that in a case such as VT a failure by the authority to escalate to the ISA Board a decision to bar a person to whom the SJP has been applied but who does not meet the barring criteria may result in a person losing a possibly crucial safeguard provided for by the authority’s internal procedures. In an ‘autobar with reps’ case the SJP is applied after representations have been received. Representations may be drafted with the provisions of the SJP specifically in mind, so that a departure from the SJP in making a barring decision on a basis not covered by the representations could result in substantial injustice. 21. Although in Nadarajah Laws LJ preferred to base the concept of legitimate expectation on the requirement for good and consistent administration rather than on the need for fairness, it is clear from Bhatt Murphy that there must nevertheless be unfairness sufficient to amount to an abuse of process for the concept of legitimate expectation to come into play. Since barring decisions will often not only affect a person’s reputation but also their livelihood, it may be that the threshold of unfairness which has to be established in such cases in order to show the breach of a legitimate expectation is lower than in cases where less vital interests are at stake. However, the provisions of the SJP form part of an administrative, rather than a judicial, decision making process, and the doctrine of legitimate expectation does not in our view confer the status of a legal procedural code on a document which has been developed to assist administrative decision makers in making barring decisions which are, to quote the ISA’s factsheet, “fair, rigorous, consistent, transparent and legitimate”
“The SJP is used for consideration of complex individual cases that cannot reasonably be concluded at an earlier stage (or progressed otherwise: see section 2.3) and is focussed on risk factors linked to future harm. Case workers must note that some of the risk factors are not, without qualification or a combination with other factors or the relevant conduct itself; inherently harmful; it is the relevance of that risk factor to the relevant conduct under consideration that will determine the whether the ISA bars an individual. For example, an emotional congruence with children is not of itself necessarily a harmful attribute but if the evidence clearly demonstrated that an individual disclosed historical instances of sexual abuse to children over a period of time because they were more comfortable engaging on an emotional level with children, this would raise legitimate concerns regarding the risk of harm that the individual posed to children in future.”