Abstract
In R. v. North and East Devon HA ex p. Coughlan the Court of Appeal significantly clarified the doctrine of substantive legitimate expectations. The facts of the case are familiar. The applicant had been very severely disabled in a road traffic accident in 1971 and was subsequently placed in the care of a local area health authority. In 1993 she and seven other seriously disabled patients were moved by the health authority with their consent to a new facility at Mardon House after receiving an assurance that they could live there “for as long as they chose”. Following a public consultation in 1998, the health authority decided to close Mardon House and transfer the applicant to a local authority home.
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