Padfield v Minister of Agriculture, Fisheries and Food
[1968] AC 997
Ratio Decidendi
A statutory discretion is never unfettered. It must be exercised to promote the policy and objects of the Act conferring it. A minister who refuses to exercise a discretion for reasons that frustrate the Act's purpose acts unlawfully — and the court can compel the minister to reconsider on lawful grounds. The case establishes that even an apparently unreviewable ministerial discretion is subject to the rule that 'unfettered' means 'undefined as to objects', not 'free from constraint as to purpose'.
তথ্য
The Agricultural Marketing Act 1958 s.19(3)(b) empowered the Minister of Agriculture, Fisheries and Food to refer to a committee of investigation any complaint about the operation of a milk marketing scheme. South-east dairy farmers complained that the pricing scheme prejudiced them because their transport costs to market were lower yet they received the same pool price. The minister refused to refer the complaint, citing 'wider issues' — but in correspondence acknowledged he feared the committee's recommendations would be embarrassing if he then declined to act on them. The farmers sought an order of mandamus compelling the minister to refer the complaint.
রায়ের সারসংক্ষেপ
The House of Lords (Lord Reid, Lord Hodson, Lord Pearce — with Lord Morris and Lord Donovan dissenting) allowed the appeal by a 3-2 majority and held the minister's refusal unlawful. The minister's reasons were improper — they showed he had used his discretion to frustrate, not to promote, the statutory scheme. The statutory power was conferred to allow grievances to be aired, and the minister was not entitled to defeat that purpose by refusing to refer for collateral political reasons. Mandamus was issued requiring the minister to consider the complaint according to law. Lord Reid emphasised that Parliament conferring an 'unfettered' discretion does not mean a discretion immune from review — it means one defined as to its objects but bounded by the Act's purpose.
মূল উদ্ধৃতি
"Parliament must have conferred the discretion with the intention that it should be used to promote the policy and objects of the Act; the policy and objects of the Act must be determined by construing the Act as a whole and construction is always a matter of law for the court."
— Lord Reid
"If the Minister, by reason of his having misconstrued the Act or for any other reason, so uses his discretion as to thwart or run counter to the policy and objects of the Act, then our law would be very defective if persons aggrieved were not entitled to the protection of the court."
— Lord Reid
"I do not think that the minister is bound to give reasons for his decision; but if he does and they show that he has misunderstood the policy of the Act, then his decision cannot stand."
— Lord Pearce
পরবর্তী ব্যবহার
The Padfield principle — that statutory discretion must be exercised for proper purposes consistent with the policy of the Act — has been applied in countless judicial review cases since 1968 and is one of the foundational doctrines of modern administrative law.
Confirmed and extended in R v Secretary of State for the Home Department, ex p Fire Brigades Union [1995] 2 AC 513 — minister cannot exercise prerogative or statutory discretion to frustrate Parliament's policy.
Routinely cited in challenges to refusals to refer matters (e.g. to the Criminal Cases Review Commission, the Competition and Markets Authority, and various ombudsmen) and in refusals to issue guidance or to give reasons.
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