Robert Bartosik, R (on the application of) v Office of the Police & Crime Commissioner for Norfolk

For judicial review proceedings, the appropriate regional venue is generally the region with which the claim has its closest connection. The court may consider the issuing court’s volume of claims, capacity, resources and workload, but those considerations do not ordinarily justify retaining a claim in a region to which it is not closely connected. A claimant’s personal links with the issuing region are not decisive where the claim’s subject matter lies elsewhere. Regional resources should generally be directed towards claims most closely connected with that region.

The claimant issued judicial review proceedings in Manchester concerning the handling by Norfolk Police and the Norfolk Police and Crime Commissioner’s Office of a complaint alleging a crime. The claimant lived in Glasgow and identified the North West as the region most closely connected with the claim. A minded-to transfer order was made, and the claimant relied on his personal connections with the North West and the volume of work in London. The defendant supported transfer. The issue was the appropriate regional venue under CPR Practice Direction 54C.

1. Venue determined. The claim was to be administered in London, as the regional venue for the South-East of England.
2. Under Civil Procedure Rules 1998 Practice Direction 54C, paragraph 2.5(f), the relevant consideration was whether it was desirable to administer the claim at the court where it had been issued, having regard to the volume of claims and that court’s capacity, resources and workload. The court also had to identify the region with which the claim had its closest connection.
3. The claim was plainly most closely connected with the South-East and London. Its subject matter concerned Norfolk public authorities and the handling of events in Norfolk. The claimant’s residence and personal links with Manchester did not establish the claim’s closest regional connection.
4. Although London had a large volume of cases, it was equipped to deal with them. The workload pressures at Manchester supported directing regional resources towards claims with their closest connection to that region. Neither the claimant’s personal links nor general caseload considerations justified retaining the claim in Manchester.

First-instance venue determination on the papers. No prior appellate decision is stated in the judgment.