{"id":644994,"date":"2026-04-22T06:46:55","date_gmt":"2026-04-22T04:46:55","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/elizabeth-soilleux-v-secretary-of-state-for-levelling-up-housing-and-communities\/"},"modified":"2026-04-22T06:46:55","modified_gmt":"2026-04-22T04:46:55","slug":"elizabeth-soilleux-v-secretary-of-state-for-levelling-up-housing-and-communities","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/ru\/jurisprudences\/elizabeth-soilleux-v-secretary-of-state-for-levelling-up-housing-and-communities\/","title":{"rendered":"Elizabeth Soilleux v Secretary of State for Levelling Up Housing and Communities"},"content":{"rendered":"
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MR JUSTICE FORDHAM: Introduction 1. These linked claims for judicial review and statutory review arise out of an application for outline planning permission S\/0202\/17\/OL (for residential development of up to 110 dwellings with areas of landscaping and public open space and associated infrastructure works) and the associated and subsequent reserved matters approval appeal APP\/W0530\/W\/22\/3291523. All of the key documents are available in the public domain by searching using the reference numbers which I have given. Any interested person wishing to know more about the context and detail, and to follow the paragraph numbers I will give, will be able to do so by finding the public domain documents. Arguability threshold 2. I deal at the outset with a preliminary point. I was invited to adopt a heightened arguability threshold because these cases have occupied a one day hearing. I agree with Ms Hutton for the Claimant that that is not an appropriate course to take. The reason why a hearing of 4 hours was allocated was because these are two linked cases (\u201csignificant\u201d planning cases), which are complex and in which a number of grounds for review have been identified. In my judgment, it is appropriate to apply the threshold of arguability with a realistic prospect of success that is entirely conventional in judicial review and statutory review; together with any discretionary bar (there is one in play in the judicial review: the question of delay). The Claims 3. The claims were commenced on 19 July 2022. The target for the claim for judicial review is the local authority\u2019s grant of outline planning permission on 26 October 2017. The grant of outline planning permission followed a detailed Officer Report dated 9 August 2017. The target for the claim for statutory review is the Secretary of State\u2019s Inspector\u2019s decision of 10 June 2022 approving the reserved matters on appeal, after an inquiry which ran from 24 May 2022 to 1 June 2022. The cast list of representatives on that appeal was set out by the Inspector at the end of the Determination and is at least as impressive (if not identical) to the cast list for these claims in this Court. The Inspector\u2019s Determination comprised 185 paragraphs and 33 pages. Permission for judicial review and leave for statutory review were refused on the papers by Thornton J on 12 October 2022. Length of the Skeleton Argument 4. An Order was subsequently made (27 October 2022) which included a 10-page restriction on the length of any skeleton argument from the Claimant. That was in the context where this Court already had extremely detailed and comprehensive pleadings, and where what the permission Judge at this hearing was really going to need most was to \u2018cut to the chase\u2019 \u2013 in writing and orally \u2013 to identify the key headline points that really mattered, in order to test the case against the relatively modest permission and leave stage arguability threshold (together with the delay point). In the event, what Ms Hutton offered the Court was a 20 page skeleton argument in the statutory review claim, together with a 10 page skeleton argument in the judicial review claim. She did so accompanied with an application for permission to vary the Order that the Court had made. Very sensibly, the statutory review skeleton argument was in two parts, the second of which was 10 pages of submissions \u2018cutting to the chase\u2019. I did not read \u2013 and did not need \u2013 the first part of that skeleton argument. That was because I was able to inform myself, by reference to other materials, of the relevant background. I formally refuse permission to rely on the first part of the skeleton argument. In my judgment the direction which had been made in this case was an appropriate discipline and it would have been sufficient to follow it. The Parameters Plan 5. I will start with the sixth of six grounds for statutory review. This raises a discrete issue about compatibility with a Parameters Plan. Castlefield (the developer) had made the reserved matters application on 13 September 2019, within the two-year timeframe permitted by the outline planning permission conditions. One of the issues raised before the Inspector (Determination \u00a711) was that the reserved matters application was not \u201cvalid\u201d and within the scope of the outline planning permission. The Inspector addressed that issue (Determination \u00a7\u00a711-20 and 184). He concluded that appropriate and \u201cacceptable\u201d changes had been made which remained in \u201cbroad conformity and harmony with the outline planning permission including the Parameters Plan\u201d (\u00a712). The Inspector made reference to the relevant \u201ccase law\u201d which had been cited on the appeal (\u00a715). 6. Ms Hutton\u2019s argument, in its essence, came to this. It is right that the test identified by Lord Denning MR in Heron Corporation v Manchester City Council [1978] 1 WLR 937 at 944C-D applies, asking whether there was departure in any \u201csignificant respect\u201d from the outline permission or conditions. However, the approach of the High Court in R (Swire) v Canterbury City Council [2022] EWHC 390 (Admin) at \u00a743, to the phrase \u201cin accordance with\u201d in the planning condition in that case (Swire \u00a736), is an approach applicable on the facts and in the circumstances of that case but inapplicable in the present case. What matters in the present case is to identify the objectively correct interpretation (Swire \u00a730) of the planning conditions and the Parameters Plan. On the legally correct interpretation of Planning Condition 4 in this case, when read alongside Planning Conditions 6 and 28, what was needed was a \u2018strict accordance\u2019 with the Parameters Plan, subject only to any \u2018de minimis\u2019 departure. That is correct bearing in mind the later planning conditions which speak of \u201cgeneral accordance\u201d (Condition 6) and a specific reserved matter arising out of the Parameters Plan (Condition 28). The Inspector went wrong in law, as a matter of interpretation of those Planning Conditions, in not accepting the \u201cstrictly accordance\u201d approach (Determination \u00a712) and, rather, adopting as permissible \u201cbroad conformity and harmony\u201d. The Inspector also went wrong in law in the objective interpretation of the Parameters Plan itself in identifying (\u00a715) ancillary infrastructure as permissible. These were material errors in the present case, where a pumping station and electricity substation had been included in what the Parameters Plan identified as \u201copen space\u201d. That constituted a material departure from the Parameters Plan which should have timed-out the reserved matters application. 7. I cannot accept that this ground is arguable with any realistic prospect of success. The Inspector identified the wording of Condition 4 (\u00a713) and considered it in its context. His approach of looking for \u201cbroad conformity and harmony\u201d was the approach directly arising from the case law, including Heron, which had been cited to him. It gave the phrase \u201cin accordance with\u201d its ordinary and natural meaning. That ordinary and natural meaning of \u201cin accordance with\u201d is what Swire identifies at \u00a743. In Swire, moreover, there were very similar arguments about a \u201ctighter\u201d approach viewed alongside another condition (Swire \u00a738), as well as arguments about the interpretation of a parameter plan (Swire \u00a748). The Inspector\u2019s conclusions (Determination \u00a7\u00a712-13) were plainly an exercise of \u201cplanning judgment and degree\u201d (Swire \u00a744). This was squarely the realms of \u201capplication\u201d rather than \u201cinterpretation\u201d. It is clear, moreover, that the points being considered at Determination \u00a712 included the pumping station and electrical substation because those had been raised in the very \u201coutline submissions on validity\u201d to which the Inspector referred. That, in my judgment, is fatal to this ground. 8. But the Inspector went on, for good measure, to pick up the stick from the other end (Determination \u00a7\u00a714-15) and consider whether, within the Parameters Plan itself, there was room for latitude. To the extent that there was, that would itself raise a question of broad conformity and harmony. Viewed independently and in that way the Inspector, in my judgment unimpeachably, also concluded that the inclusive wording of the Parameters Plan was not prohibitory of ancillary infrastructure in open spaces (\u00a715). But even if this second aspect were arguably erroneous in public law terms the earlier passage (\u00a7\u00a712-13) is fatal for the reasons I have identified. The Flooding Concerns 9. The other grounds for statutory review and judicial review all relate to increased risk of off-site flooding. There are relevant planning policies concerning flood risk. These were identified at the outline planning permission stage in the Officer Report of August 2017 (Report \u00a7\u00a79-13), where flood risk was identified as one of the key material considerations (Report p.1) and where it was addressed in the passage at \u00a7\u00a7116-117. There was a Flood Risk Assessment dated September 2014 and a January 2017 Update, appending an August 2016 Report. The lead local flood authority had responded on 15 February 2017. Castlefield\u2019s position in the application form for outline planning permission (\u00a712) was that the proposal would not \u201cincrease the flood risk elsewhere\u201d. That remained its position in the application for reserved matters approval. 10. The point that emerges in this case and emerged before the Inspector and has been at the heart of the flood risk concern is, as I see it, as follows. Figure 4.7, when compared with Figure 4.3, in the August 2016 report appended to the January 2017 Update showed an increase in the extent and\/or depth of potential flooding to the south of the site into the Cow Lane gardens when the position with, and without, the development was compared. That picture arose using a \u201c1 in 100 year\u201d modelling method with a \u201cclimate change\u201d adjustment. This came to be recorded in the submissions before the Inspector on behalf of the Save Fulbourn Fields and Fulbourn Forum as properly considered by all parties as \u201cthe appropriate measure of probability\u201d. There were equivalent Figures 4.7 and 4.3 in later reports: in particular an August 2020 Report and a subsequent April 2022 Report. Mr Turney emphasises from Castlefield\u2019s perspective that further materials were deployed to show, at a glance, what the ultimate Figure 4.7\/4.3 comparison picture showed. Ms Hutton submits that the point ultimately came into clear focus and \u2013 she says \u2013 finally accepted on behalf of Castlefield through cross-examination to which she showed me a reference in written submissions before the Inspector. The concern at the heart of this case, as I see it, arises out of what those various pictures show so far as concerns increase in extent and\/or depth of water inundating parts of Cow Lane gardens. The Figure 4.7\/4.3 comparison, of the picture with and without the development, allows a focus on the implications for flooding of the development. 11. In the Inspector\u2019s Determination the issue of \u201cflood risk\u201d was recorded as one of the \u201cmain issues\u201d which had been raised (\u00a732). The Inspector heard a lot of evidence about it, as well as submissions, and gave detailed reasons. Scope of Reserved Matters Approval 12. One line of reasoning in the Inspector\u2019s Determination was that \u201cflood risk management\u201d was not a \u201creserved matter\u201d but one which went to the \u201cprinciple of development\u201d, for consideration at the earlier outline planning permission stage, where indeed it had expressly been considered; and that reserved matters approval was concerned with \u201cappearance, landscaping, layout and scale\u201d (Determination \u00a7\u00a783, 86, 88, 106 and 182). The first ground for statutory review is that the Inspector made an error of law as to whether the increased risk of off-site flooding fell within the scope of reserved matters approval. Ms Hutton submits that the increased risk of off-site flooding and flood risk management were within the reserved matters. She says in the present case they were intimately linked to both landscape and layout. She says that everybody approached the issue of flooding and flood risk management as being relevant (as she submits, rightly); and that the development proposals were designed and revised at the Reserved Matters Approval stage, to attenuate floodwater. She accepts that the Inspector went on in the Determination to deal with the topic of increased risk of off-site flooding. But she submits that there was nevertheless a \u201cmaterial\u201d error by the Inspector in relation to the scope of the reserved matters. When pressed, her submission was that the \u2018materiality\u2019 was \u2018because of the modelling\u2019. She went on to emphasise, on this and other parts of the case, that the Inspector did not require, through Conditions, the replication in delivery of the same \u201clandform\u201d as had been the subject of the modelling. As she put it, if the Inspector was going to go on and find the flood risk position to be \u201cacceptable\u201d he needed to secure the \u201clandform\u201d by reference to which that view had been arrived at. 13. In my judgment, it is not arguable with any realistic prospect of success that there was any error of law, still less material error of law, on the part of the Inspector so far as the scope of the reserved matters is concerned. In my judgment, in the passages in which the Inspector recorded (eg. \u00a786) that \u201cthe potential for flood risk\u201d was \u201cnot a reserved matter\u201d but had \u201calready been considered, in principle, as part of the outline planning permission\u201d, the Inspector was adopting a position which was, \u201cin principle\u201d, correct in law. Flood risk, \u201cin principle\u201d, had been settled at the outline planning permission stage, in the context of the principle of development, except insofar as flood risk related to landscaping and layout. Put another way, the starting point was that \u201cin principle\u201d the development was acceptable in flood risk terms. 14. But, in any event, the point can \u2013 in my judgment \u2013 go nowhere in the circumstances of the present case. The Inspector did not exclude increased risk of off-site flooding and flood risk management from consideration. Rather, he addressed it in a lengthy and sustained passage within the Determination. Indeed, the Inspector \u2013 in my judgment and beyond argument \u2013 went as far as dealing, on its planning merits, with the increased risk of off-site flooding concerns that had been raised with him. He emphasised (\u00a786) that he was being invited to consider that aspect of the development proposals. In my judgment, beyond argument, that is plainly what he went on to do. That is why for example passages that come later are linked with a phrase like \u201cnotwithstanding the above\u201d (\u00a789). In my judgment, there are passages (eg \u00a7\u00a790-93) where the Inspector is grappling, head-on, with the picture from the modelling (\u00a790), with the concerns about \u201cdepth and extent of water during a period of flood\u201d (\u00a792) that were being raised with him, on the materials as they were before him, and that he was doing so on the \u2018planning merits\u2019. Ultimately, he arrived at this conclusion (at \u00a797): I am also satisfied that the proposal would not result in a flood risk to neighbouring land or properties. I interpose, in the same vein, that the Inspector recorded (at \u00a792) \u201cI do not agree with [the Forum] that the reserved matters application form is incorrect from the point of view of saying that the proposal would not increase \u2018flood risk\u2019 elsewhere\u201d; and (at \u00a7111) that \u201cthe available evidence before me does not indicate that this proposal would result in a flood risk elsewhere\u201d. In light of that structure, and reasoning, in my judgment it is impossible with a realistic prospect of success to argue that a \u2018material\u2019 error was present in the approach to the scope of the reserved matters, whatever the position on that topic. So far as concerns the \u2018materiality\u2019 arising \u2018because of the modelling\u2019 I confess I am unable to see how points relating to modelling render this aspect of the case arguably \u2018material\u2019, given the approach which the Inspector took and to which I have just referred. As to requiring replication of the landform through Conditions, since this point arose in relation to various grounds for statutory review, I will deal with it at this stage. Conditions Replicating the Modelled Landform 15. As I indicated, Ms Hutton submitted that the Inspector went wrong in public law terms in not requiring the delivery of the landform which was the basis of the modelling on which he was persuaded of flood risk acceptability. Ms Hutton submits that, although the Forum did ask for a planning condition to be imposed relating to flood risk and did not ask for this landform-replication condition, nevertheless it could not be expected to do so and in any event it was a matter for the Inspector. She also says the Inspector would have needed more information. In my judgment, it is highly material \u2013 to what must be an unreasonableness challenge \u2013 that, in all the detailed submissions to the Inspector as to what course needed to be taken, including submissions relating to a planning condition said to be needed to be imposed (with which he dealt at Determination \u00a7182) \u2013 that there was no request along the lines of what Ms Hutton now repeatedly submits was obvious and required by public law reasonableness. Even leaving that aspect to one side, Mr Glenister for the Secretary of State has shown me what \u2013 on the face of it \u2013 are a series of new Conditions imposed by the Inspector (Determination \u00a7185) which touch on this aspect of the case: New Conditions 1, 16, 17 and 19. He submits that this demonstrates the Inspector conscientiously addressing aspects of securing delivery in the context of the findings he had made. In my judgment, save for a general submission that there should have been a single Condition to replicate \u201cthe landform\u201d, there was in the response on the behalf of the Claimant nothing by way of illustration of how it is that those Conditions leave outstanding some important \u201clandform\u201d aspect. Ultimately, it is \u2013 in my judgment \u2013 impossible to say that the course taken by the Inspector, in relation to what further Conditions were and were not imposed, arguably crosses the threshold of unreasonableness in the context of the planning judgment and evaluation entrusted to him. Judicial Review 16. As I have explained, the Inspector\u2019s Determination specifically recorded that the flood risk issue had been raised by the local authority and third parties and the Inspector considered it appropriate to address the issue (Determination \u00a7\u00a782, 86 and 89). The Inspector also addressed what the position had been before the local authority at the outline planning permission stage. He explained that he was satisfied that the issue of flood risk had expressly been considered (\u00a7\u00a783, 86, 182). He explained (at \u00a783) that the \u201cinformation submitted by [Castlefield] and considered by the local planning authority and the [lead local flood authority], did show an increased extent\/depth of flood to the south of the site into gardens on Cow Lane\u201d (where the Claimant lives). He also explained that the position taken by the local authority (and the lead local flood authority) was that it \u201cagreed that the proposal would not increase \u2018flood risk\u2019 elsewhere\u201d (\u00a7\u00a783, 182). All of this takes me next into the realms of the claim for judicial review. 17. The ground for judicial review, in a claim for which a four-year extension of time would be necessary, addresses that topic. The argument advanced is this. The information did indeed \u201cshow an increased extent\/depth of flood to the south of the site into gardens on Cow Lane\u201d. It was indeed the position taken by Castlefield and the local authority that \u201cthe proposal would not increase \u2018flood risk\u2019 elsewhere\u201d. But this amounted to a misappreciation on the part of the local authority and planning officer, and a misstatement on the part of Castlefield. A relevant consideration was overlooked or alternatively a material error of fact made. That misappreciation and misstatement have emerged in this case. The modelling information available at the time of the Officer Report did show (the Figure 4.7\/4.3 comparison) the increased incidence in extent and\/or depth, with the development compared to without. But that position was materially misstated by Castlefield. Not only did it describe the avoidance of increasing off-site \u201cflood risk\u201d but it also referred to the development as one with a layout plan which served \u201cto avoid diverting the floodwater elsewhere\u201d, a layout \u201cbased around the need to provide space for surface water runoff shed from the surrounding development (run-on) and for runoff generated by the proposed development itself (run-off)\u201d, so that \u201cby making space for water the proposals avoid the potential displacement of run-on to the surrounding development\u201d. The Officer Report was itself materially misleading and left uncorrected because it made no mention of the picture which Figure 4.7 of the modelling work evidenced. That was an undoubtedly material, as it went to the fact of flooding. The absence of any mention deprived the local authority of the opportunity to reach a planning judgment on that aspect. Whether viewed as a relevant consideration or materially misleading Officer Report, or for that matter a material error of fact, the outline planning permission grant in October 2017 is vitiated as a matter of public law. All that is needed for today is that this is arguable. 18. So far as delay is concerned Ms Hutton submits in essence as follows. The Claimant could not, or not realistically, bring her judicial review claim earlier than she did. She did not, on the evidence, appreciate the implications of the Figure 4.7 modelling data until October 2019, at which point the concerns \u201ccrystallised\u201d. By that time, there was the extant application made the previous month for reserved matters approval. The Claimant took the position that this point could be addressed through the reserved matters application process. Everything that subsequently happened reinforced that point of view. For that reason, instead of attempting a belated judicial review claim, she sensibly and understandably put her \u2018eggs in the basket\u2019 of arguing the point on the reserved matters application and appeal. Although the Inspector did deal in the Determination with the point that had been raised, he did not do so properly. The Inspector\u2019s view \u2013 as Ms Hutton put it in her reply \u2013 was in any event a \u2018new\u2019 development and could not be a basis for refusing a remedy in judicial review. And there are a number of flaws in the way in which the Inspector dealt with the issue. 19. I am going to refuse permission for judicial review. The starting point is the discretionary bar. This is a plain and obvious case of extreme delay. The delay of now nearly five years, more than four years at the time when judicial review proceedings were commenced, is to be viewed against the six week timeframe identified in the Civil Procedure Rules 54.5(5). I do not accept the submission that the Claimant \u201ccould not\u201d have brought a claim on this point promptly. I pressed Ms Hutton on whether she was submitting that this was a \u201cconcealment\u201d case. She does not submit that there was a concealment; nor could she in light of the fact that the modelling documents were produced and in the public domain. She does submit that the position was materially misstated, both by the developer and in the Officer Report. But it would have been possible to make that very point in a judicial review challenge, promptly, to the grant of outline planning permission. I cannot accept, at least in the absence of concealment, that ignorance can be an excuse in those circumstances. There is, moreover, a clear detriment to good administration and plainly a clear prejudice to the interests of Castlefield who, on the evidence, has spent more than \u00a31m on this project subsequent to that unchallenged grant of outline planning permission. 20. Delay, in my judgment, has a second dimension which is also, and independently, fatal. The Claimant\u2019s explanation for why she took the course that she did, and excusing the delay, is that she put her eggs in the basket of the Inspector dealing with this point through the reserved matters application and appeal. I understand that entirely. But that is precisely what the Inspector did in passages in the Determination to which I have already referred. In my judgment, beyond argument, the Inspector did consider \u2013 on the \u2018planning merits\u2019 \u2013 the \u2018increased risk of off-site flooding\u2019 issues. The Inspector concluded that the policy position, so far as that aspect of the application was concerned, is that the consequences were acceptable, and in terms concluded that there is no policy \u201cconflict\u201d (Determination \u00a7111). What I cannot accept is that the Claimant was entitled to pursue this course: not to bring judicial review, deciding instead to raise points at the reserved matters stage asking the Inspector to deal with them; then, when the Inspector does so adversely, on the \u2018planning merits\u2019, to seek then to bring a judicial review to reopen the decision on outline planning permission reached by the local authority more than four years earlier. That, in my judgment, is itself a fatal aspect of the delay objection to this claim for permission for judicial review. To the extent that there is anything in the criticisms that the Inspector did not look at issues \u2018properly\u2019 but made a public law error in the Determination, those can of course be raised \u2013 and are being raised \u2013 in the application for statutory review of the Inspector\u2019s Determination. 21. Finally, on this delay aspect of the case, it is relevant to remember \u2013 as I have explained \u2013 that the Inspector also evaluated the position as it stood at the time of outline planning permission. Having heard detailed evidence and submissions, the Inspector concluded that this issue was expressly considered by the local authority (Determination \u00a7\u00a783, 86, 182), that the information from Castlefield did show increased potential for flooding to the Cow Lane Gardens (\u00a783) at the time of outline planning permission, that the local authority (and the lead local flood authority) had agreed that there was no increased flood risk elsewhere (\u00a7\u00a783, 182). 22. Leaving aside the issue of delay, I cannot in any event see an arguable basis for the claim that this feature of the information and material from the developer was overlooked by planning officers or needed to be spelled out in the Officer Report. That point links to the ground to which I will come next in the context of the statutory review claim, about what is meant by \u201cflood risk\u201d. It is also relevant that the local authority appears in these proceedings, with a duty of candour, and if there were material in the possession of the local authority to support the conclusion that it had been \u201cmaterially misled\u201d by what Castlefield said, I would expect it to be brought to the Court\u2019s attention. Mr Beglan, for the local authority, has very properly confirmed that \u2013 from his client\u2019s perspective \u2013 the duty of candour is regarded as being applicable at this permission stage. 23. In light of all of that there, is in my judgment, no need to invoke either common law \u2018inevitability\u2019 or the statutory HL:NSD (highly likely: not substantially different) tests. However, the point is compellingly made by Mr Beglan that, in the light of the planning Inspector\u2019s clear evaluation as a matter of planning merits of the acceptability of the development in terms of flood risk, there would need to be some very good reason why the local authority \u2013 even were this matter reopened and remitted \u2013 would take a different \u2018planning merits\u2019 review. None has been identified. \u201cFlood Risk\u201d 24. The third ground for statutory review, and the one to which I have just alluded, involves an alleged error of law. Ms Hutton, in essence, submits that a \u201cflood risk\u201d is the same as \u2018land being covered by water\u2019 and that the Inspector made a material error of law in his approach to \u201cflood risk\u201d. The relevant \u201cflood risk\u201d policies are CC9 (of the South Cambridgeshire Local Plan) and NPPF (National Planning Policy Framework) \u00a7167. The relevant definitional description, replicated in the PPG (National Planning Policy Guidance) was set out by the Inspector in the Determination (at \u00a791): for the purposes of applying the National Planning Policy Framework, flood risk is a combination of the probability and the potential consequences of flooding from all sources \u2013 including from rivers and the sea, directly from rainfall on the ground surface and rising groundwater, overwhelmed sewers and drainage systems, and from reservoirs, canals and lakes and other artificial sources. There is no dispute that this was a legally correct starting point, so far as the meaning of \u201cflood risk\u201d is concerned. 25. Ms Hutton submits that an \u2018increased probability of flooding\u2019 is itself a sufficient \u201cconsequence\u201d as to satisfy the meaning of \u201cflood risk\u201d as correctly interpreted. She accepts there may be other \u201cconsequences\u201d but the existence and presence of an increased body of water, or water over a greater geographical area, or at a greater depth, or for a longer period of time, would all \u2013 of themselves \u2013 fall within \u201cflood risk\u201d as correctly interpreted. She submits that \u201cprobability\u201d gives you the \u2018how often\u2019 but the \u201cconsequence\u201d is met by \u2018how much\u2019 water is present. She also emphasises that, under the relevant policies, what matters is to ensure no increase to flood risk \u201celsewhere\u201d, which means \u201canywhere\u201d. In support of her interpretation of \u201cflood risk\u201d she referred me to R (Menston Action Group) v City of Bradford Metropolitan District Council [2016] EWHC 127 (QB) [2016] PTSR 466 \u00a7\u00a72-16 but she acknowledged that that is no more than \u201cconsistent\u201d with her approach and doesn\u2019t grapple with the issue with which I am concerned. She submitted that it would \u201cmake a mockery\u201d of the planning application if a developer could tick the box to say \u201cno flood risk\u201d notwithstanding there would be a known greater incidence of volume of water. She emphasised that no policy guidance calibrates the way in which one looks at the other \u201cconsequences\u201d. She submits that, at least arguably, the Inspector therefore went wrong in law in those passages where he said (Determination \u00a783) Land being covered by water is not, itself, an occurrence of \u2018flood risk\u2019. And (Determination \u00a792): I acknowledge that gardens would be covered by the identified depth and extent of water during the period of flood, but this would be a temporary inconvenience. I do not find that the extent and depth of such water would amount to a \u2018flood risk\u2019 \u2026 She also submits that, even if that is wrong, there is an arguable unreasonableness in the Inspector\u2019s approach in regarding as a \u201ctemporary inconvenience\u201d the nature of the increased incidence of water inundating gardens in Cow Lane, in light of all the evidence and in light of concerns including as to personal safety and children. 26. In my judgment, there is no arguable error of law or arguable unreasonableness in the approach or analysis of the Inspector in the Determination. The correct definition, as I have said, was identified and set out (\u00a791). The nature of that definition shows, beyond argument, that when the word \u201crisk\u201d is used, in the context of \u201cflood risk\u201d, the word \u201crisk\u201d does not mean simply the probability of a flood or of flooding. It is plain that flood \u201crisk\u201d brings into play harmful \u201cconsequences\u201d. In my judgment, it is not arguable that the mere presence of water or an increased amount of water, in and of itself, must constitute a \u201cflood risk\u201d for the purposes of the policies, correctly interpreted. The presence of water constitutes the \u201cflood\u201d and the \u201crisk\u201d arises as a function of \u201cconsequence\u201d in light of the \u201cprobability\u201d. That separate element \u2013 \u201cconsequences\u201d \u2013 is clearly present and necessary, for good reason, and in my judgment the Inspector did not \u2013 even arguably \u2013 misunderstand its significance as a matter of interpretation. I do not accept, even arguably, that this makes a \u201cmockery\u201d of the planning application or that there is anything in the point about policy guidance. The planning applicant can be expected to indicate in relation to this matter, as with any other relevant matter, the position that is taken in relation to the application. But that position can then be scrutinised, to see whether the application falls foul of relevant parameters in relevant policies. There is no question of the planning applicant being able, through the ticking of a box, to be able to avoid scrutiny by reference to any relevant policy standard. The policy guidance point in my judgment goes nowhere. On any view, it must be relevant to be able to consider adverse consequences and a number of them are identified in the PPG description. If Ms Hutton is right that no policy guidance assistance addresses the way in which that exercise undertaken then that point, as it seems to me, is at best neutral. It cannot answer the question of interpretation. 27. But, even if I put that to one side and assume that there was some arguable misinterpretation, the fundamental problem in this case which remains is this. The Inspector addressed his mind to questions of acceptability in light of the evidence about the gardens risking being covered with the identified depth and extent of water during a period of flood. That is inevitably where the \u2018planning merits\u2019 would have led and that is where he went. His conclusion was that that position was not unacceptable in planning terms. His assessment is that it would constitute a \u201ctemporary inconvenience\u201d (Determination \u00a792). He went on to emphasise that the gardens were not \u201csensitive receptors\u201d (\u00a792) and he emphasised that there was no evidence of any risk to the \u201cdwellings\u201d (\u00a7\u00a792-93). As I have already explained, he went on to conclude that there was no incompatibility or conflict with policy. In light of all of that, this \u2013 in my judgment \u2013 is a misinterpretation ground which cannot fly, even if it can get out of the starting blocks. I was shown various materials as to the positions taken on the appeal before the Inspector but the important point about those, in my judgment, was that there was a debate about whether a threshold of harm was applicable to \u201cconsequences\u201d. That was in circumstances where one suggestion was a test of \u2018intolerability\u2019. The local authority took the position, in its submissions to the Inspector, that this was not the appropriate approach. Nor did the Inspector adopt that approach. Betterment 28. That leaves three remaining grounds for statutory review, with which I still need to deal. Ground two is a point about \u201cbetterment\u201d. This arises out of a comparison, but not between the picture with the development being undertaken and in its absence. Rather, it is a comparison between the picture as it stood at the time of outline planning permission and the (improved) picture as it stood at the time of the Inspector\u2019s reserved matters decision. The Claimant\u2019s argument, in its essence, is that the Inspector could not \u2013compatibly with public law duties \u2013 base his decision on that comparison with the position as at outline planning permission stage. That is, in particular, because of the features relating to the Officer Report having not recorded for the Planning Committee the modelling picture from Figure 4.7. Absent an analysis of that position, says Ms Hutton, the Inspector could not lawfully or rationally base his decision on the \u201cbetterment\u201d comparison. The first answer to that point is that, in principle, it is relevant and logical at the reserved matters stage to pose a comparison question by reference to the outline planning permission stage. Particularly in circumstances where the Inspector did undertake an enquiry into what had happened at that earlier stage. I have already explained that the Inspector specifically reasoned (Determination \u00a783) that the issue had been expressly considered, that the \u201cinformation \u2026 did show an increased extent\/depth of flood to the couth of the site into gardens on Cow Lane\u201d, and that the local authority and lead local flood authority \u201cagreed that the proposal would not increase \u2018flood risk\u2019 elsewhere\u201d. But, as with the other points, this one falls away in any event. That is because the comparison which is criticised in relation to \u201cbetterment\u201d \u2013 that is to say an improved position, in the Inspector\u2019s assessment, compared to the outline planning permission stage \u2013 was not the \u201cbasis\u201d (still less the sole basis) of the Inspector\u2019s Determination. Rather, it was one distinct strand of the reasoning (Determination \u00a7\u00a785, 90, 94, 111). In the passages to which I have already referred, the Inspector specifically addressed whether the proposal would result in flood risk to neighbouring land or properties and whether that risk and that flooding profile would be unacceptable in terms of planning merits. In those circumstances, even if there were anything otherwise in the \u201cbetterment\u201d points, it could not be a vitiating flaw when this decision is properly understood. \u2018Unaddressed Issues\u2019 29. Ground four identified nine issues set out in the Claimant\u2019s skeleton argument relating to the modelling, six of nine of which are said to have been \u2018unaddressed\u2019 by the Inspector in the Determination. There was also a criticism of one passage (Determination \u00a798) in which, having identified those three of those nine aspects, the Inspector relied on Planning Condition 8 relating to surface water drainage. Finally, on this part of the case, it was argued that the Inspector had misappreciated that the lead local flood authority had expressed its view on information which was later replaced with other information. All of this is said, either individually or cumulatively, to give rise to an arguable legal inadequacy in the Inspector\u2019s reasoning. 30. In my judgment, this too raises no viable ground of challenge with a realistic prospect of success. It is a classic example of the need to read the Determination fairly and as a whole, and in circumstances where the public law reasons duty requires the Inspector to grapple with the principal controversial issues. There is, in my judgment, nothing in the criticism of the point made about Condition 8 at the end of Determination \u00a798. Having listed three matters relating to the model, the Inspectors words were carefully chosen. What he said was: Nevertheless, some of these matters, so far as they are relevant to surface water drainage, will need to be fully checked and verified by the [lead local flood authority] as part of the consideration of an application to discharge Condition 8 of the outline planning permission. Moreover, I cannot accept that there was no prospect at all of any potential overlap between the points which he had just listed (at \u00a798) and the question of \u201csurface water drainage\u201d. So far as concerns the sequence of events and the lead local flood authority, there are two passages in which the Inspector expressly mentioned that sequence (\u00a7\u00a7100 and 106). He plainly had that well in mind, in noting the position of the lead local flood authority and attributing to it the weight that he considered appropriate. I can see no arguable public law flaw on this ground of the case. Surface Water Drainage: Planning Condition 8 31. Finally, the same position arises in relation to the final ground: statutory review ground five. This too was a point about reasoning, said to be legally inadequate, or alternatively to involve a material error of fact. Here, the argument certainly circles around Planning Condition 8, to which I have just referred. That was the Planning Condition concerned with the aspect of surface water drainage. Ms Hutton submits that there is a clear and important distinction: between flooding impact and flood risk management on the one hand; and surface water drainage on the other. She submits that, at least so far as the modelling was concerned, these were entirely distinct with no overlap, because of the way in which the modelling had been approached. She criticises the various passages in which the Inspector referred to Planning Condition 8. Foremost among them was Determination \u00a793, in discussing the prospect of flooding to the gardens in Cow Lane where the Inspector was addressing \u201cpost-traumatic stress disorder potential should properties be flooded\u201d. At that point he said: condition 8 of the outline planning permission provides a mechanism by which development cannot commence until any surface water drainage issues have been acceptably eradicated. He went on to repeat a point about no risk to flooding on the evidence to dwellings. Elsewhere in the Determination he addresses the surface water drainage aspect, observing that that strategy provides an alternative mechanism (\u00a784) and sufficient control (\u00a786). 32. I cannot accept, even arguably, that the Inspector made a public law error in the way in which he discussed the issues of \u201csurface water drainage\u201d and \u201cflood risk\u201d. He recognised that these are two distinct aspects. He referred (\u00a782) to the question whether \u201cthe reserved matters proposal can provide a satisfactory scheme of surface water drainage and prevent the increased risk of flooding\u201d. He said (\u00a789): \u201cIn this case, a compelling case has not been made that, in principle, a satisfactory surface water drainage scheme could not be submitted for the site and that the development would not be capable of being made safe for its lifetime without increasing flood \u2018risk\u2019 elsewhere\u201d. He discussed the two things alongside each other for the very sensible reason that there is clearly scope for an interrelationship between the two. I was shown by Mr Turney the passage in the Forum\u2019s own submissions where that point was strongly emphasised. I cannot accept, even arguably, that the Inspector in the decision was basing his decision on the fact that Condition 8 was available and operative and would need to be addressed. His reasons would have been very differently expressed, and much shorter, had that been his analysis. Rather this was one of the strands in a multi-faceted reasoned analysis in the exercise of evaluative judgment. Finally, I record that I was shown by Mr Turney that the model involves a catchment which does not exclude rainfall on the site (as at one point was being suggested by Ms Hutton). Conclusion 33. Notwithstanding that the threshold for today is arguability, notwithstanding that this is a case involving a host of detailed points that have been advanced, and notwithstanding \u2013 given the complexity and in light of the sustained and comprehensive written and oral submissions that have been put forward \u2013 this ex tempore Judgment is a lengthy one for the permission stage, my clear conclusion is that there is no realistic prospect of success in either the statutory review or the judicial review claims; and the judicial review claim fails for the additional delay reason. In agreement with Thornton J, who dealt with these applications on the papers, I will refuse leave for statutory review and permission for judicial review. The only consequential matter was that it was common ground that it is appropriate that I confirm the provisional Aarhus costs orders made by Thornton J: \u00a35,000 in favour of the local authority (judicial review) and \u00a35,000 in favour of the Secretary of State (statutory review). 2.2.23<\/p>\n<\/div>\n

\n

Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence (The National Archives).<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

MR JUSTICE FORDHAM: Introduction 1. These linked claims for judicial review and statutory review arise out of an application for outline planning permission S\/0202\/17\/OL (for residential development of up to 110 dwellings with areas of landscaping and public open space and associated infrastructure works) and the associated and subsequent reserved matters approval appeal APP\/W0530\/W\/22\/3291523. All of the key documents are…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7938],"kji_chamber":[],"kji_year":[24566],"kji_subject":[7612],"kji_keyword":[13324,17930,11227,7696,7881],"kji_language":[7611],"class_list":["post-644994","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-high-court-planning-court","kji_year-24566","kji_subject-fiscal","kji_keyword-determination","kji_keyword-flood","kji_keyword-inspector","kji_keyword-planning","kji_keyword-review","kji_language-anglais"],"yoast_head":"\nElizabeth Soilleux v Secretary of State for Levelling Up Housing and Communities - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/ru\/jurisprudences\/elizabeth-soilleux-v-secretary-of-state-for-levelling-up-housing-and-communities\/\" \/>\n<meta property=\"og:locale\" content=\"ru_RU\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Elizabeth Soilleux v Secretary of State for Levelling Up Housing and Communities\" \/>\n<meta property=\"og:description\" content=\"MR JUSTICE FORDHAM: Introduction 1. 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