{"id":598114,"date":"2026-04-18T23:00:32","date_gmt":"2026-04-18T21:00:32","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/ag-v-brent-council\/"},"modified":"2026-04-18T23:00:32","modified_gmt":"2026-04-18T21:00:32","slug":"ag-v-brent-council","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/ag-v-brent-council\/","title":{"rendered":"AG v Brent Council"},"content":{"rendered":"
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The decision of the Upper Tribunal is to allow the appeal in part. The decision of the First-tier Tribunal dated 15 May 2023 under number EH304\/22\/00032 involved the making of an error on a point of law. However, the decision is not set aside. REASONS FOR THE DECISION 1. In what follows references to a. the \u201ctribunal\u201d and to the \u201cdecision\u201d are to the First-tier Tribunal and its decision as referred to immediately above; b. numbers in square brackets are references to paragraphs of the tribunal\u2019s decision (unless otherwise indicated); and c. \u201cs\u201d or \u201csection\u201d are to sections of Children and Families Act 2014 (unless otherwise indicated). The Appellant\u2019s appeal to the tribunal 2. The appeal concerned the Appellant\u2019s son, a boy of 9 (at the time of the decision), whom I will refer to as \u201cS\u201d. The decision records that S had diagnoses of autism and global developmental delay. The decision also found that S\u2019s parents were separated and lived at different addresses; S lived with his mother during the week and stayed with his father, the Appellant, on weekends and every second Monday evening. 3. The appeal to the tribunal, made under s51(2)(c), was against the contents of the EHC plan made for S by the Respondent and communicated to him by letter on 11 April 2022. The appeal concerned Sections B, F, C, G, D and H1 and H2 of S\u2019s EHC plan. 4. The Appellant was not legally represented at the tribunal hearing; he represented himself. S\u2019s mother was a witness on behalf of the Respondent. 5. The tribunal dismissed the Appellant\u2019s appeal. The Upper Tribunal proceedings 6. Acting inquisitorially, the Upper Tribunal procured, from the tribunal, electronic copies of the documents before the tribunal at the Appellant\u2019s appeal. 7. On 3 November 2023, the Upper Tribunal issued my decision (following reconsideration at an oral hearing) granting the Appellant permission to appeal on the sole ground that the tribunal arguably erred in law by not adequately explaining why, in making recommendations as to the content of sections D and H2 of S\u2019s EHC plan, it recommended giving S's mother sole discretion over what social care activities S should access (so rejecting the Appellant\u2019s argument, recorded at [30], that he be included in any social care provision). 8. The permission decision included the following background to the ground on which permission was given: \u201cTribunal\u2019s recommendations as regards social care 17. The relevant wording from S\u2019s EHC plan as approved by the tribunal, was as follows: Section D: S is supported by Brent Social Care in accordance with a Child in Need Plan. The 0-25 Disabled Children and Young People Service. The allocated worker will work closely with the family and S to ensure that the appropriate support is in place. This will be reviewed in line with the borough\u2019s Short Breaks process. S is currently in process of receiving 6 hours per week. This is provided through Direct payments which allows flexibility of services for S to access by [S\u2019s mother] choosing which activities S should access. This could be D A R E every Saturday. Alternatively It could be in line with activities of interests or linked to S\u2019s hobbies etc. Section H2: S is currently under a Short Breaks structure which allows regular social work visits, and multi professional meeting where the current care package would also be reviewed. Following this, the request of services would then be presented to Disabled Children and Young People\u2019s Resource Panel. S is currently in process of receiving 6 hours per week. This is provided through Direct payments which allows flexibility of services for S to access by [S\u2019s mother] choosing which activities S should access. This could be D A R E every Saturday. Alternatively It could be in line with activities of interests or linked to S\u2019s hobbies etc. Further context from the tribunal bundle 18. By way of context, I note the following from the tribunal bundle: a. the \u201ccfa\u201d report by the Respondent says (at page 551): 14 October 2020: Child Arrangement Order granted. Both child[ren] to remain in the care of their mother and have contact with their father. Contact arrangement staggered until it gets to 2 overnight contacts once per 2 weeks. b. an email from [the Appellant] to the tribunal of 30 September 2022 says: \u201cI must make it clear to the Tribunal that both parents have a Live With Court order. Both parents have equal rights. How much time the child spends with each parent per week during the school term (for your information, the children spend an equal amount of time with each parent during non-school terms) does not affect or override the rights and responsibilities of one parent or make one parent more or less important. The LA is constantly suggesting this to abstract and sideline the father to the detriment of a special needs child. The LA was rebuked by a family court for suggesting this previously. There is no primary and secondary carer or parent.\u201d c. page 34 of the tribunal bundle ([the Appellant]\u2019s \u201capplication for appeal\u201d) says: \u201cFamily court ordered in 2021 both parents (father and mother) have to live with order and parental responsibilities\u201d. How the tribunal\u2019s decision dealt with the social care issue 19. At [21], \u201csocial care to include both parents\u201d was listed (under the heading, Section D) as an issue between the parties (as was, at [22], under the heading Section H2, the need for regular social work visits and the short breaks structure). 20. At [30], under the heading Evidence, the tribunal\u2019s decision recorded that [the Appellant] wished to be included in any social care provision; he did not agree that he had been contacted by the social worker. At [32], the decision recorded the social worker\u2019s evidence that she had attempted to contact [the Appellant] but he did not respond; she had not therefore been able to obtain his perspective on the level of support needed. At [35], it recorded S\u2019s mother\u2019s evidence that [the Appellant] refused to be involved with social workers and did not want them to be involved with S. 21. At [51], the tribunal gave its decision on the sections of S\u2019s EHC plan dealing with social care. It said it deleted [the Appellant]\u2019s allegations about Brent social care because it was not health provision reasonably required by the learning difficulties which result in S having special educational needs (and so did not belong in that section of the EHC plan). It said it had reinstated the Respondent\u2019s description of S's social care needs and his social care provision. It said that no relevant evidence was submitted by the Appellant to contradict the Respondent\u2019s wording in those sections. Why I have decided there is an arguable error of law with regard to how the tribunal\u2019s decision dealt with this issue 22. The powers of the tribunal on appeal are, amongst other things, to make recommendation that the social care needs and\/or provision should be specified, or amended, in an EHC plan. There is Upper Tribunal authority (e.g. BB v London Borough of Barnet [2019] UKUT 285 (AAC) at [8], and other cases cited there) to say that, in performing this (and its other) functions, the tribunal should give effect to s19. 23. [the Appellant]\u2019s arguments seemed mostly aimed at showing that the Respondent had failed to give effect to s19; this may or may not be the case, but it does not assist him in showing any arguable error of law on the part of thetribunal. 24. However, it became clear in the course of the oral hearing that [the Appellant]\u2019s underlying complaint was that the tribunal had recommended that S\u2019s mother be given sole discretion over the social work activities to be undertaken by S. 25. It seems to me realistically arguable that the tribunal\u2019s decision did not adequately explain at [51] (or elsewhere) why it had decided to make this recommendation, in the face of [the Appellant]\u2019s arguments that he should be involved ([51] does say that the Respondent\u2019s wording was adopted \u201cbecause no relevant evidence was submitted\u201d by the Appellant to contradict it, but this, arguably, does not address the point, as it is not a matter of \u201cevidence\u201d). One can hypothesise as to why the tribunal took the course it did: given the state of relations between the parents, it perhaps thought that it needed one or other of the parents to make these decisions, and preferred the mother, as, on the face of it, she had been more cooperative with social services. However, the tribunal\u2019s thinking on this is not explained; and it seems to me realistically arguable that the tribunal could have taken other courses in the circumstances, such as: a. refraining from giving either parent a sole discretion, and instead specifying itself what social care activities were to be recommended; or b. giving [the Appellant] some say in these matters. It seems to me arguable that the decision erred in law by not explaining this matter adequately, on the well-known principle that a party must be given to understand why it has lost a case, in part so it can test whether there is an error of law in the underlying analysis. 26. I have not articulated this ground in terms of s19 as, without adequate explanation of why it recommended that S\u2019s mother be given sole discretion in this matter, it is difficult to know whether or not the tribunal took that section into account.\u201d 9. The Respondent made responses to the appeal on 17 and 22 January 2024. The Appellant made a reply to these, on 22 January 2024. In directions issued on 8 March 2024, I made the following observations: \u201cI am concerned that both the Respondent\u2019s response, and [the Appellant]\u2019s reply, paid insufficient attention to the following important points: 1. The purpose of this appeal before the Upper Tribunal is to decide whether there was a material error of law in the decision of the First-tier Tribunal of 15 May 2023. The purpose is not, for example, to determine whether the Respondent complied with section 19 Children and Families Act 2014. If there was such an error of law in the First-tier Tribunal\u2019s decision, the Upper Tribunal will then have to go on to consider whether or not to set aside the First-tier Tribunal\u2019s decision and, if it does, whether to remake the decision itself, or remit the case back to the First-tier Tribunal for reconsideration. Both parties to the appeal must focus their argument on the above issues. 2. The only ground on which permission to appeal has been given is that stated at the beginning of the permission decision: \u201cthat the First-tier Tribunal arguably erred in law by not adequately explaining why, in making recommendations as to the content of sections D and H2 of the Applicant\u2019s son\u2019s EHC plan, it recommended giving the son\u2019s mother sole discretion over what social care activities S should access (so rejecting the Applicant\u2019s argument, recorded at paragraph 30 of the First-tier Tribunal\u2019s decision, that he be included in any social care provision).\u201d Both parties to the appeal must focus their argument on this ground. It is not readily apparent to me why evidence of what has happened subsequent to the issuance of the First-tier Tribunal\u2019s decision, or indeed any evidence that was not before the First-tier Tribunal, is relevant to the ground as set out above. Any party wishing the Upper Tribunal to rely on such evidence will therefore need to explain (in their skeleton argument and\/or in their oral submissions at the hearing, as per the directions below) why they think it is relevant to the ground of appeal.\u201d 10. I am grateful to both the Appellant and to Ms Thompson for their written and oral arguments in preparation for, and at, the hearing on 8 May 2024. Some relevant law Social care needs and social care provision in an EHC plan 11. Section D of an EHC plan sets out the child\u2019s \u201csocial care needs which relate to their special educational needs or to a disability\u201d (regulation 12(1)(d) Special Educational Needs and Disability Regulations 2014) 12. Section H2 sets out \u201cany other social care provision reasonably required by the learning difficulties or disabilities which result in the child \u2026 having special educational needs\u201d (regulation 12(1)(h)(ii) of those regulations). \u201cSocial care provision\u201d means the provision made by a local authority in the exercise of its social services functions (s21(4)). 13. In an appeal such as the Appellant\u2019s, the tribunal had the power to recommend that Sections D and\/or H2 of S\u2019s EHC plan be amended or that certain social care needs or social care provision be specified (regulations 4 and 5 Special Educational Needs and Disability (First-tier Tribunal Recommendations Power) Regulations 2017). Adequacy of reasons 14. There are many well-known authorities on adequacy of reasons. The Respondent cited Meek v City of Birmingham DC [1987] IRLR 250, where Lord Bingham (thein in the Court of Appeal) said (at paragraph 8): It has on a number of occasions been made plain that the decision of an Industrial Tribunal is not required to be an elaborate formalistic product of a refined legal draftsmanship but it must contain an outline of the story which has given rise to the complaint and a summary of the tribunal\u2019s basic factual conclusions and a statement of the reasons which led them to reach the conclusion which they do so 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 the reasoning to enable the EAT or on further appeal this court to see whether the question of law arises\u2026 15. As this appeal concerns certain arguable \u201cgaps\u201d in the tribunal\u2019s reasoning, I have also borne in mind the following well-known principles: a. the reasons of the tribunal must be considered as a whole. b. the appellate court should not limit itself to what is explicitly shown on the face of the decision; it should also have regard to that which is implicit in the decision. R v Immigration Appeal Tribunal, ex parte Khan [1983] QB 790 (per Lord Lane CJ at page 794) was cited by Floyd LJ in UT (Sri Lanka) v SSHD [2019] EWCA Civ 1095 at [27] as explaining that the issues which a tribunal decides and the basis on which the tribunal reaches its decision may be set out directly or by inference. c. the following was said in English v Emery Reimbold & Strick Ltd [2002] 1 WLR 2409 (a classic authority on the adequacy of reasons), on the question of the context in which apparently inadequate reasons of a trial judge are to be read: \u201c26. Where permission is granted to appeal on the grounds that the judgment does not contain adequate reasons, the appellate court should first review the judgment, in the context of the material evidence and submissions at the trial, in order to determine whether, when all of these are considered, it is apparent why the judge reached the decision that he did. If satisfied that the reason is apparent and that it is a valid basis for the judgment, the appeal will be dismissed. \u2026 If despite this exercise the reason for the decision is not apparent, then the appeal court will have to decide whether itself to proceed to a rehearing or to direct a new trial. \u2026. 118. … There are two lessons to be drawn from these appeals. The first is that, while it is perfectly acceptable for reasons to be set out briefly in a judgment, it is the duty of the judge to produce a judgment that gives a clear explanation for his or her order. The second is that an unsuccessful party should not seek to upset a judgment on the ground of inadequacy of reasons unless, despite the advantage of considering the judgment with knowledge of the evidence given and submissions made at the trial, that party is unable to understand why it is that the judge has reached an adverse decision.\u201d Why I have decided that the ground of appeal is made out Parties\u2019 main submissions 16. The Respondent argued that the tribunal had adequately explained why it decided to give S\u2019s mother sole discretion over what social care activities S could access: as the decision stated at [51] (explaining why it reinstated the Respondent\u2019s description of S\u2019s social care needs and his social care provision), the Appellant had not adduced relevant evidence to contradict that wording. 17. The Appellant pointed to the wording he had sought to insert at Section D of S\u2019s EHC plan (and in the particular the underlined passages below, as supporting his argument that he had provided the tribunal with a positive proposal as to social care): \u201cS\u2019s safeguarding and welfare issues must be the utmost priority when coming into contact with allocated workers from Brent Social Care. The constant change of support workers and social workers with no experience of working with children who have Autism and learning difficulties has caused emotional and mental harm to S and his sister. The harm that is been done by the current social worker to S and his sister can not be taken lightly. It will not be to the best interest of S for the tribunal to give this social worker the cover to continue to do harm. The support from Brent social care must be to support S in the generalisation of social, communication and OT skills taught to situations outside of the school and also to support him with his academic progress. The support that Brent social care provides for S is inconsistent and sometimes not in the best interest of S. Any future support provided must be in consultation with both parents and advice from the professionals that support S at school. Brent social care claim: \u2018The allocated worker will work closely with the family and S to ensure that the appropriate support is in place\u2019. This claim is false. Brent Social Care, as can be seen in their proposal for this EHCP documents and the report submitted as evidence to the tribunal, they have lost sight of working to the best interest of S because of their desire to isolate and marginalise a parent. As stated above, any future support provided must be in consultation with both parents and advice from professionals that support S at school.\u201d 18. The Respondent contended that the Appellant\u2019s wording \u201csimply sought to criticise the Respondent, with no evidence to support those assertions\u201d; and that the Appellant \u201cdid not make any amendments to the working document to identify the social care provision that he believed was required\u201d; nor did he \u201cput forward any evidence or information as to the activities he would like S to access\u201d; the Respondent submitted that, per the evidence before the tribunal, the Appellant \u201cdid not want S to access social care provision\u201d (paragraph 16 of their skeleton). 19. The Respondent\u2019s arguments rested heavily on evidence summarised at [32], in the section of the decision under the heading Evidence, where the tribunal recorded evidence given by the Respondent\u2019s social worker at the hearing to the effect that \u201c\u2026 she agreed that both parents needed to be considered in relation to social care provision. She said that she had attempted to contact the Appellant but he did not respond. She was not therefore able to obtain his perspective on the level of support required.\u201d 20. The Respondent also pointed to evidence in the tribunal bundle, being the social worker\u2019s \u201ccfa\u201d (child and family) assessment from February 2023, which said (in the \u201canalysis and recommendation\u201d section) as follows: \u201cA new social work assessment was requested due to S being in Tribunal. The purpose of the assessment was to obtain a holistic perspective from each family member where possible and to ensure that the assessment captures the family's needs well. Unfortunately this has not been the case as [the Appellant] has not engaged with\u00a0the assessment process and wishes\u00a0no social care involvement. [The Appellant]'s perspectives would have been key as he has raised concerns that S would benefit from being within an alternative school provision. [The Appellant] has also shared with the social worker that he does not wish for Social Workers to be involved with his children as he believes it is not positive for S.\u201d 21. The Respondent contended that because the Appellant had been uncooperative with, and highly critical of, Brent social services, this meant that the Appellant did not want S to access any social care provision \u2013 and so, to give him any say over social care provision would be perverse. VS and RS v Hampshire CC [2021] UKUT 187 (AAC) was said to be relevant, as it \u201caccepted that, where a Tribunal does not have sufficient evidence before it to make recommendations in respect of social care provision, then it is reasonable for it not to do so \u2013 so long as that is clearly stated\u201d. The Respondent submitted that the Appellant \u201chad a clear objection to social care input\u201d and \u201cdid not want to engage with the service\u201d, and so \u201cthe only reasonable response\u201d was to give S\u2019s mother, alone, power to choose the activities S should access. The Respondent contended that it would not have been appropriate for the tribunal itself to specify social care provision activities, as this would \u201cunnecessarily have restricted the provision that S could access\u201d. To involve the Appellant in choosing social care activities for S \u201cwithout any evidence as to what that might look like, would leave the provision at risk of breaking down\u201d, which plainly would not be in S\u2019s interests. Upper Tribunal\u2019s analysis 22. On the face of it, the decision\u2019s reason for recommending that S\u2019s mother be given sole discretion over what social care activities S should access \u2013 despite the decision acknowledging, at [30], that the Appellant, as S\u2019s father, wanted to be involved as well \u2013 was an absence of \u201crelevant evidence\u201d from the Appellant. What the decision seemed to have in mind in terms of \u201cevidence\u201d that the Appellant could have submitted, but did not, was evidence of the kinds of social care activities he would (positively) want S to take part in (as the Respondent pointed out, part of the Appellant\u2019s suggested Section D wording consisted of complaints about Brent social services\u2019 input to date). This reasoning seems to me problematic: a. if the allegedly \u201cmissing\u201d evidence (from the Appellant) was evidence specifying exactly what social care activities S should access, then this was entirely at odds with the social care provision that the decision ultimately decided was required, as that, too, was not \u201cspecific\u201d in this respect, but rather gave S\u2019s mother (alone) the right to choose social care activities; b. the absence of such \u201cevidence\u201d cannot, therefore, be a rational, or fair, explanation for why the decision gave S\u2019s mother that sole discretion; c. if the true explanation was that the tribunal had reasoned that, given the Appellant\u2019s strongly-worded complaints about Brent social services to date, it was likely that he would \u201cblock\u201d any social care activities if he had any role in choosing them, then this is in turn problematic because i. the decision had itself recorded (at [30]) that the Appellant had said that he wanted to be involved in social care provision for S (and the decision had not made any findings to the effect that, if involved, the Appellant would simply \u201cblock\u201d any social care activities); and ii. the Appellant\u2019s suggested wording at Section D did not, on the face of it, object to any social care activities, but rather required, in future, consultation with both parents and \u201cprofessionals\u201d supporting S at school. 23. In essence, the decision\u2019s reasons are in my view inadequate on this point because they do not engage with what the Appellant actually suggested in his proposed wording (as above: consultation with parents plus \u201cprofessionals\u201d) \u2013 and, it would appear from [30], at the tribunal hearing \u2013 and do not explain why the tribunal rejected this. The explanation cannot, logically, be (as it appears to be on the face of [51]) that the Appellant\u2019s proposal was not specific enough, as the tribunal went on to recommend something of no greater specificity (that S\u2019s mother choose the social care activities); and it cannot be inferred from the context (such as the evidence given and submissions made at the tribunal) that the tribunal had decided, on the basis of the Appellant\u2019s complaints about Brent social services\u2019 input so far, that he would block any social care activities (as this would be an important, and sensitive, finding for it to make \u2013 and it did not make it). Moreover, such a finding (about expected obstruction by the Appellant to any social care activity) would not fully explain why the tribunal gave S\u2019s mother sole discretion over social activities, as the Appellant\u2019s proposals also gave \u201cprofessionals\u201d from school a say in choosing such activities, and there is no explanation of why this aspect was rejected in the decision. 24. The result is that the Appellant is left without fairly understanding why he lost on this point; and the appellate tribunal is unable to probe as to whether there was legal error in the tribunal\u2019s thinking in arriving at its conclusion. It follows that there is material legal error in the decision on this point. Respondent\u2019s alternative arguments 25. The Respondent submitted that even if the tribunal erred in law by inadequately explaining this aspect of its decision, the error was immaterial because \u201cany alternative proposal would have been fraught with difficulties and impossible to implement in any practical sense\u201d; the Respondent alluded in particular to the difficulty of deciding who should receive the \u201cdirect payments\u201d (that pay for social care activities). 26. In my view, these are assertions about what the tribunal would inevitably have found \u2013 but are unsupported by any findings actually made by the tribunal. It is similar to the point made above about the tribunal not having made a finding about the Appellant\u2019s \u2018obstruction\u2019 of any social care activity: had such a finding been made, then the Respondent\u2019s point here would have traction. But no such finding was made; nor can it fairly be inferred. 27. The Respondent made a further argument in the alternative, to the effect that, \u201cin S\u2019s case, Section H2 does not actually identify the provision that S should receive; it only states what he is receiving i.e. it is simply a matter of fact.\u201d 28. I cannot accept this argument: in law, Section H2 sets out the social care provision reasonably required. This section of S\u2019s EHC plan cannot be said to be a mere description of present circumstances. Section 19 29. The Respondent cited S v Worcs CC (SEN) [2017] UKUT 0092 (AAC), where, at paragraphs 70-73, the Upper Tribunal considered a ground of appeal based on s19 (concerning the need to have regard to views, wishes and feelings \u2013 in this case, it was the views etc of the child that were at issue): 70. I am not persuaded by the local authority\u2019s argument that the section 19 obligations cannot apply to the First-tier Tribunal because they are high-level strategic functions that could not have been intended to apply to the Tribunal. They are not strategic functions. They are obligations which apply to and are designed for the benefit of specific children and young persons. 71. Nevertheless, this was an appeal brought by a young person. It was Robbie\u2019s appeal. Dealing with his case inevitably involved the Tribunal having regard to his views, wishes and feelings. I do not accept that the Tribunal failed to give adequate reasons for not following his wishes. While the Tribunal did not in terms explain why it would not implement his wishes, it explained why it rejected his case which amounts to the same thing. This ground does not succeed. 72. The participation and enabling aspects of section 19 did not feature prominently in argument. However, if the First-tier Tribunal discharges its obligations under its procedural rules, including the overriding objective, it will be doing as much as would be required if it were subject to the section 19 obligations. 73. For the above reasons, by way of general guidance to the First-tier Tribunal I do not see any need for it to complicate its business by expressly seeking to act in accordance with section 19 of the CFA 2014. It should simply act in accordance with the overriding objective and, if it does, will be acting in the spirit of section 19. 30. I agree that this appeal does not succeed on grounds of breach of s19 by the tribunal (and, indeed, permission to appeal was not given on such ground). Why I have refrained from setting aside the tribunal\u2019s decision 31. Given the nature of the error of law in the decision that has been identified, my inclination, had I set the decision aside, would have been to remit the case back to the tribunal for reconsideration \u2013 it would not have been appropriate to remake the decision myself. 32. The Respondent submitted that such course of action would have been purely academic, because the EHC plan which was the subject matter of the decision had, in effect, been superseded by a new EHC plan for S, which was issued on 14 February 2024, and which contained identical social care provisions to those which are the subject matter of this appeal; the Appellant had notified an appeal against that new EHCP plan; and that there was to be a hearing of that new appeal to the tribunal, in due course. 33. I agree that to remit this case back to the tribunal would be an academic exercise in these circumstances; I therefore refrain from setting the decision aside (which would have forced me to choose between remitting, and redeciding). My hope and expectation is that this decision will be placed before the tribunal considering the Appellant\u2019s \u201cnew\u201d appeal, so that the points made in it can be borne in mind when deciding that appeal. Zachary Citron Judge of the Upper Tribunal Authorised for issue 6 June 2024<\/p>\n<\/div>\n

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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":"

The decision of the Upper Tribunal is to allow the appeal in part. The decision of the First-tier Tribunal dated 15 May 2023 under number EH304\/22\/00032 involved the making of an error on a point of law. However, the decision is not set aside. REASONS FOR THE DECISION 1. In what follows references to a. the \u201ctribunal\u201d and to the…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[9033],"kji_chamber":[],"kji_year":[8677],"kji_subject":[7612],"kji_keyword":[7705,7633,7634,9706,7636],"kji_language":[7611],"class_list":["post-598114","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-upper-tribunal-administrative-appeals-chamber","kji_year-8677","kji_subject-fiscal","kji_keyword-appeal","kji_keyword-appellant","kji_keyword-respondent","kji_keyword-social","kji_keyword-tribunal","kji_language-anglais"],"yoast_head":"\nAG v Brent Council - 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\/zh-hans\/jurisprudences\/ag-v-brent-council\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"AG v Brent Council\" \/>\n<meta property=\"og:description\" content=\"The decision of the Upper Tribunal is to allow the appeal in part. The decision of the First-tier Tribunal dated 15 May 2023 under number EH304\/22\/00032 involved the making of an error on a point of law. However, the decision is not set aside. REASONS FOR THE DECISION 1. 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