Andrew Michael Wardley, R (on the application of) v General Medical Council

Administrative Court judicial review claims should ordinarily be administered and determined in the region with which they have the closest connection. The assessment focuses principally on the claim’s subject matter, the claimant’s place of residence and the defendant’s relevant location. The court may also consider practical and case-management factors, including travel, cost, video-link facilities, public interest, court capacity and the location of legal representatives. A claimant’s preference for London will not displace that general expectation without sufficiently supported reasons.

The claimant issued a judicial review claim in London challenging the General Medical Council’s decision to communicate regulatory concerns about him to a third-party responsible officer. The claimant lived in Huddersfield and explained that London had been chosen because of location, access and ongoing medical treatment.

A minded-to-transfer order proposed transfer to the Administrative Court in the North-Eastern region, to be administered and determined at Leeds. The claimant opposed transfer, while the General Medical Council took a neutral position. The issue was whether Leeds or London was the appropriate venue under Practice Direction 54C.

1. The claim was transferred to the North-Eastern region, to be administered and determined at Leeds.

2. Under Practice Direction 54C, claims should, where possible, be administered and determined in the region with which they have the closest connection. The relevant assessment includes the subject matter of the claim, the region in which the claimant resides, and the region in which the defendant or a relevant office or department is based.

3. The claim was most closely connected with the North-Eastern region. The claimant lived in Huddersfield, and the subject matter concerned his relationship with his professional regulator. Although the General Medical Council had headquarters in London, it had offices nationally and its legal team was based in Manchester.

4. The additional factors in paragraph 2.5 supported transfer. Travel to Leeds was easier and cheaper for the claimant and the defendant’s legal representatives. Leeds also had suitable video-link facilities. The claim could be administered and determined there by specialist or visiting High Court judges.

5. The claimant’s asserted medical treatment did not justify retaining the claim in London. The available evidence did not establish its nature, frequency or any difficulty attending a hearing in Leeds, particularly given the claimant’s residence near Leeds.

The judgment records that the claim was issued in London on 27 August 2024. A minded-to-transfer order was made on 3 December 2024, followed by written submissions from the parties. The Administrative Court then ordered transfer to the North-Eastern region, to be administered and determined at Leeds.