Valery Sawbridge, R (on the application of) v Leeds District Magistrates Court

Judicial review claims should ordinarily be dealt with at the regional Administrative Court venue most closely connected with them. A claimant’s complaints about judges, court staff or a court centre do not, without more, establish actual or objectively justified apparent bias, or show that the regional court cannot deal with the claim properly and justly. Specific concerns about a judge or the consequences of a complaint may be raised and considered when they arise.

The claimant sought judicial review of decisions made by Leeds District Magistrates’ Court on 4 October 2023, including decisions concerning bail and the entry of a plea. He also raised issues concerning free representation and translated documents.

The claim was filed in London although the claimant lived in Pontefract and the claim was most closely connected with West and East Yorkshire. He said that ongoing complaints involving the Leeds judiciary, court staff and the Leeds Combined Court Centre required the claim to be heard in London to ensure an impartial tribunal. The issue before the court was whether there was sufficient reason to retain the claim in London rather than transfer it to the Administrative Court in Leeds.

1. Transfer ordered. The claim was transferred to the Administrative Court in Leeds. The court was not deciding the merits or viability of the proposed judicial review.
2. The court proceeded without deciding whether the claimant had in fact made the complaints described. It was sufficient to proceed on the basis that any complaint made would be addressed on its merits.
3. There was no basis for concluding, or for an objectively justified perception, that no judge sitting in the Administrative Court at Leeds could deal properly, justly and appropriately with the claim. The existence of complaints about the judiciary, court staff or the court centre did not itself establish a conflict, bias or institutional inability to determine the claim fairly.
4. If a previous case involving the claimant gave rise to a specific concern, that concern could be considered. If a complaint was said to have a particular consequence, the claimant could raise that issue. Those possibilities did not justify transferring the case to London at this stage.
5. Judicial review claims should be dealt with at the regional venue with which they are most closely connected, absent some very good reason. No such reason existed here.

Not an appeal. The judgment determined the venue for a judicial review claim filed in London and transferred it to the regional Administrative Court in Leeds.