Facts: the Secretary of State decided to close the Independent Living Fund (ILF), devolving funding for the purpose of sustaining independent living to local social services authorities. The claimant contended that consultation had been unlawful and that the Secretary of State had failed to discharge the PSED.

Judgment: The Court of Appeal (Elias, Kitchin and McCombe LJJ) held that the consultation had been adequate in that consultees had had an adequate opportunity of explaining the likely effect on them of the closure of the fund and it had not been necessary to provide them with financial information about the costs associated with closure of the ILF or to explain more than that the reason for the proposal was to achieve an integrated care system and economies of scale.