Associated Provincial Picture Houses v. Wednesbury Corporation

Facts

• Sunday Entertainments Act 1932 empowered local authorities to license cinemas on Sundays subject to "such conditions as the authority thinks fit"
• Wednesbury Corporation granted cinema license with condition: no children under 15 admitted on Sundays
• Cinema company challenged condition as unreasonable
• No specific statutory ground for the condition; it was purely discretionary

Issue

1. On what grounds can a court review a discretionary administrative decision for "unreasonableness"?

Held

• Courts cannot substitute their own view for that of the authority
• A decision is reviewable only on narrow grounds: (a) authority took into account irrelevant factors; (b) ignored relevant factors; (c) the decision is "so unreasonable that no reasonable authority could ever have come to it"
• The third ground (absurdity/outrageous defiance of logic) is the "Wednesbury unreasonableness" standard
• On facts: the condition was within range of permissible responses; not so absurd that no reasonable body could impose it
• Challenge dismissed

Ratio Decidendi

When statute confers discretion on an authority in broad terms ("as it thinks fit"), courts will not interfere merely because they disagree with the decision. Intervention occurs only at the extremes: where the outcome is so irrational that something must have gone wrong in the reasoning process. This high threshold respects the separation of powers and administrative expertise.