Venkateshwarlu Bandla, R (on the application of) v Harwood Group Practice (Determination as to Venue)

Venue for an Administrative Court claim is determined by identifying the region with which the claim is most closely connected, having regard to the subject matter and the locations of the claimant and defendant. The court must also consider other relevant circumstances, including convenience and cost, alternative hearing arrangements, court resources and whether related proceedings should be heard together. A related claim in another region may be highly persuasive, but it does not automatically require transfer where the claim’s principal connections, the parties’ convenience and other circumstances favour retaining the proceedings in their current region.

The claimant sought judicial review of his GP practice’s refusal to issue a medical fitness certificate. He issued the claim in the Manchester Administrative Court because both parties were based in the North West.

An Administrative Court Lawyer issued a minded to transfer order proposing transfer to the South Eastern Region. The proposed transfer reflected the connection with another claim brought by the claimant in London. The claimant opposed transfer; the defendant made no submissions. The issue was whether the claim should remain in Manchester or be administered and determined in another region under CPR PD 54C.

1. Venue. The claim was to remain in Manchester. The court had to determine the region with which it was most closely connected by reference to paragraphs 2.1 and 2.5 of CPR PD 54C.
2. The claimant lived in Bolton, the defendant was based there, and the subject matter was a dispute between the claimant and his GP practice. Those factors connected the claim most closely with the Northern Circuit region.
3. The claimant’s reasons concerning cost and convenience were relevant. Because both parties represented themselves, requiring travel to London would create additional cost and inconvenience. The factors concerning alternative means of attendance, public interest, expedition, court capacity, devolution issues and representatives’ location were neutral or inapplicable.
4. The related London claim was a highly persuasive factor in favour of transfer under paragraph 2.5(g). Nevertheless, transfer was unnecessary. The strong local connections favoured Manchester, the existence of the claim could be recorded on the London court system, and the claim appeared close to resolution.
5. The claim therefore remained in Manchester.

This was a first-instance judicial determination on venue. A minded to transfer order had been issued by an Administrative Court Lawyer on 25 February 2025, inviting written submissions before the final decision. Mrs Justice Hill determined the issue on the papers and retained the claim in Manchester.