Jurisdiction(s):
United Kingdom

Administrative Court grants permission and interim relief in age assessment JR; claimant treated as putative child; s20 CA 1989 support; American Cyanamid applied; anonymity and expedition (England and Wales)

Published on: 27 November 2025

Published by a LexisNexis Local Government expert

Legal News

Article summary

R (on the application of Master Zo) (a child by his litigation friend, AK of the Refugee Council)) v Hounslow London Borough Council [2025] EWHC 3008 (Admin)

What are the practical implications of this case?

The practical implications of this case are as follows:

A clear reminder to practitioners of the permission threshold: where the material before the court, even taken at its highest for the Claimant, discloses a factual case that could not properly succeed at a contested factual hearing, permission must be refused; in all other circumstances, permission should be granted (R(FZ) v London Borough of Croydon [2011] EWCA Civ 59).
In relation to injunctions, the court confirmed there is no hard-edged rule in age assessment claims requiring a strong prima facie case; showing a triable issue may suffice, notwithstanding that the relief sought could be viewed as a mandatory injunction (R(AS) v Liverpool City Council [2020] EWHC 3531 (Admin)).

These points underscore both the correct approach to the permission stage and the flexible standard applicable to interim relief in age assessment disputes, aligning with the cited authorities while preserving a fact-sensitive assessment by the court...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...