Facts: Mr E had a learning disability and was a long-stay hospital patient, assessed as being suitable for re-settlement in the community. However, over a period of 11 years, only two offers of accommodation in the community, both unsuitable, had been made.

Judgment: McCloskey J held that, in Northern Ireland, there was a statutory duty to assess apparent community care needs, that there was a legitimate expectation that such assessments would normally be completed in accordance with the People First guidance and that the relevant authorities were under a resource-free duty to meet assessed needs. In the case of JR 47, and others, those duties had been breached.