Abstract
In December 2021 the Court of Appeal (Civil Division) published its ruling in Worcestershire County Council, R (On the Application Of) v Secretary of State for Health and Social Care [2021] EWCA Civ 1957, a case about a dispute between two local authorities regarding which of them should bear the duty to provide after-care for a patient (service user) following her discharge from her second detention under section 3 of the Mental Health Act 1983. The primary issue in the case was where she was ordinarily resident at the time of her second detention under s 3 of the Mental Health Act 1983. This paper reviews the case, surveys the evolution of the duty to provide after-care and comments on specific aspects of the Court of Appeal's decision.
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