High Court emphasizes regional connection in judicial review venue decision

Citation: [2023] EWHC 3216 (Admin)
Judgment on


The High Court of Justice has issued a judgment concerning the proper venue for a judicial review within the Administrative Court system. This case, Adam Bale, R (on the application of) v Commissioners for HMRC, elucidates upon the criteria and public interest considerations that underpin determinations on where a claim should be heard. The court emphasizes the importance of claims being heard in the region most closely connected to them and criticizes the default use of the London Administrative Court as a primary venue. In this analysis, we will dissect the summary provided to understand the key topics, legal principles, and outcomes of the case.

Key Facts

The claim for judicial review was filed in London by the claimant from the Wirral, Merseyside, implicating a personal liability notice imposed by HMRC concerning alleged discrepancies in PAYE returns with a significant penalty. Despite the case’s apparent connections to the North-West region, both parties resisted a proposed transfer from London to the Manchester Administrative Court. The parties provided several arguments against the move, focusing on the geographical location of legal counsel and the cost and administrative implications of such a transfer.

The court in its judgment addressed several legal principles central to the determination of venue:

  1. Connection to the Region: Courts must evaluate the claim’s connection to the region when deciding the appropriate venue for a judicial review. In the present case, the claim forms indicate a preference for London without proper justification, as the claim has stronger ties with the North-West region ([2023] EWHC 3216 (Admin), para 5-6).

  2. Public Interest Consideration: It is in the public interest that the regional venue corresponding most closely with the claim should hear the matter. This principle asserts that the venue should not be decided based on the capital’s status or on any perceived hierarchy within the Administrative Court system ([2023] EWHC 3216 (Admin), para 7).

  3. Choice of Lawyers: The selection of lawyers, whether based in London or another region, should not drive the venue for a judicial review. Ensuring that the Administrative Court’s integrity and ethos as a national court are not compromised is paramount ([2023] EWHC 3216 (Admin), para 7-10).

  4. Venue Determination and Case Management: In instances where venue choice might be contentious, it is advisable for parties to seek a prompt determination of venue from the court. This principle is underscored by referencing other judgments, such as R (Ellis) v SS for Education [2022] EWHC 1263 (Admin) and Bhimsinhji Thakor v SSHD [2022] EWHC 2556 (Admin), to exemplify past applications of this practice ([2023] EWHC 3216 (Admin), para 11-13).


Applying these principles, the court concluded that the default venue in London was not justified and transferred the claim to the Manchester Administrative Court. The court recognized the importance of cost consideration but deemed them unsubstantial given the claim’s value and the fact that legal representatives were willing to incur travel and accommodation costs to attend meetings in London. The transfer decision accentuates that overarching considerations of regional connection and public interest outweigh the convenience factors of parties involved.


The High Court’s judgment in the case of Adam Bale v Commissioners for HMRC underlines the notion that judicial reviews should be conducted in venues with the closest geographical and contextual ties to the claim. This decision reaffirms the principles of fair access to justice and effective case management within the UK’s judicial system. Legal professionals across the UK should take note of the rationale employed, emphasizing the significance of diligence in determining the most closely connected region when initiating proceedings, as well as acknowledging the court’s prerogative in reinforcing the integrity and unbiased operation of the Administrative Court’s regional venues.

Related Summaries