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Principle or Pragmatism: The Use of Supplementary Decision Letters in Judicial Review Proceedings and the Function of the Reviewing Court

1. Is it permissible for a defendant in judicial review proceedings to seek to defend its decision with the assistance of a so-called supplementary decision letter issued after the commencement of those proceedings? If so, what approach should the reviewing court adopt to such letters at the substantive judicial review hearing? How can the court protect the legitimate interests of those who challenge a decision made by a public authority only to find out during the litigation, perhaps at a late stage, that the defendant has sought to supplement the reasons for its decision? These issues recently arose before the Court of Appeal in Caroopen and Myrie v Secretary of State for the Home Department [2016] EWCA Civ 1307. This article reviews the tension between principle and pragmatism in this context and considers the practical implications of the guidance given by the Court of Appeal.