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所有案例
Administrative Law
House of Lords
1995

R v Secretary of State for the Home Department, ex parte Fire Brigades Union

[1995] 2 AC 513

判决理由

A minister cannot use prerogative powers to frustrate the will of Parliament by introducing a scheme that effectively prevents a statutory scheme from being brought into force.

事实

The Criminal Injuries Compensation Act 1995 was enacted but not brought into force. The Home Secretary instead introduced a less generous tariff-based scheme under the prerogative.

判决摘要

The House of Lords held the Home Secretary had acted unlawfully. He could not use prerogative powers to introduce a scheme that was inconsistent with and pre-empted the statutory scheme Parliament had enacted.

关键引述

"It would be most improper for the executive to use prerogative powers to frustrate the will of Parliament as expressed in a statute."

Lord Browne-Wilkinson

后续处理

Good law

Authority on the limits of prerogative power where Parliament has legislated.