Padfield v Minister of Agriculture, Fisheries and Food

Facts

• Agricultural Marketing Act 1958 gave the Minister power to refer complaints about milk pricing to a committee of investigation
• Padfield and other farmers complained that the milk marketing scheme operated against their interests
• The Minister refused to refer the complaint, giving no adequate reasons
• The refusal appeared motivated by political inconvenience rather than statutory grounds

Issues

1. Could the Minister refuse to refer the complaint on the ground that the matter was politically inconvenient?
2. Does a discretion conferred by statute have to be exercised consistently with the purposes of the Act?

Held

• The House of Lords held that the Minister's refusal was unlawful. Parliament had conferred the power on the Minister to further the purposes of the Act; it was not given to the Minister to use as he saw fit in his own interest or to avoid political inconvenience. Refusing to refer a complaint on the ground that it might embarrass the Minister was an abuse of the statutory discretion.

Ratio Decidendi

A statutory discretion must be exercised to advance the purposes for which Parliament conferred it. An authority that exercises a discretion to frustrate those purposes, or for extraneous reasons such as political convenience, acts unlawfully. Lord Reid: if the Minister so uses his discretion as to thwart or run counter to the policy of the Act, the court must interfere.