LA Spotlight

At the end of April, Bevan Brittan says "a fond farewell and happy retirement” to Judith Barnes, Local Government Partner, and well-known personality within the local government community. Join us, as we say farewell to Judith and hear her reflections of 38 years in local government…

Judith Barnes      A look back at 38 years in Local Government

Judith Barnes, Partner

As I hit the landmark age of 60 in April 2021, apart from hanging up the law books to play more golf and travel the world, it has caused me to reflect on the last 38 years of both working for five local authorities, and together with many more.

As you all know, every local authority is different, having been shaped by the people, the topography, the culture and events that have occurred over time. Strong local leaders have left strong legacies – here in particular I think of Sir John Harman, Leader of Kirklees Council from 1986 to 1999 who brought a vision of regeneration and growth, delivering a new stadium for the rugby and football clubs; town centre regeneration and other development through a 50:50 JV Kirklees Henry Boot Partnership Ltd; and affordable housing through Kirklees Community Association among many other achievements. I learned that significant projects and improvements are achievable provided the purpose is clear, the plan or strategy stacks up and by working together and taking calculated risks (that are regularly reviewed) through decent project management, good projects, jobs and regeneration are delivered.

I also thought about how different yet in some ways similar the 1990s were. For example, in 1983, when I started work:

  • The first Apple computers were launched
  • The Austin Metro was the best-selling UK car
  • Seatbelts became compulsory
  • Women were protesting outside Greenham Common for nuclear disarmament
  • Big shoulder pads and ruffs were in fashion
  • Margaret Thatcher won a landslide majority of 144 for her second term in office
  • There was record unemployment and
  • Mobile phones were the size of a house brick!

Challenges were similar then to now, including:

  • Record unemployment
  • Prosperity of the economy
  • Defence of the nation (more Covid related than arms at present), and
  • Reductions in public spending requiring significant cuts (principally from local authorities).

The enduring thought is that local authorities are flexible, resilient, adaptable and committed to serving their local population and will survive, if not thrive, with a clear vision, a can-do attitude and strong governance and project management to “build back better”. I leave you in the capable hands of the Bevan Brittan team including David Kitson, Victoria Barman and Mark Robinson on governance related issues, as I go off into the sunset.


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Delivering Value

Build Back Better: Pointers for Public Procurement – Transport Infrastructure

Alongside the recent Budget the Government published a policy paper (Build Back Better: our plan for growth) outlining proposals for how public spending will support post-pandemic recovery and contribute towards long-term targets and priorities. In this article we will take a quick look at some of the implications and opportunities in the transport infrastructure sector.

An important part of the levelling up agenda has been to increase connections and improve transport links between cities. HS2 is the flagship policy in this regard however the Government also remains keen to forge ahead with developing regional links. In last year’s spending review £4.2bn was dedicated to funding regional intra-city transport settlements and this year’s budget took steps towards implementing that commitment with initial funds confirmed for Greater Manchester, Liverpool City Region, Sheffield City Region, Tees Valley, West of England, West Midlands and West Yorkshire. The plan for growth outlines more transport infrastructure priorities including the A66 Northern Trans-Pennine upgrade (road) and the Northumberland Line (rail), both of which are identified as pathfinders for “Project Speed”. In addition, the Department for Transport is currently asking for bids for funding from the Restoring Your Railway Fund, allowing local authorities and community groups to develop plans for the reinstatement of local services and restoration of closed stations.

Rail in particular is a key focus of Project Speed with the government recently challenging the rail industry to develop new ways of working to halve the time and reduce the costs of rail infrastructure projects as part of its Project Speed approach. For its part the Government is to also publish a Union Connectivity Review which will make recommendations as to transport infrastructure aimed at levelling up regional inequalities. In addition, as we have covered previously, the current Public Procurement Green Paper envisages substantial changes to the existing public procurement regime. In the plan for growth the rationale for these changes is identified as being (in part) to increase regulatory flexibility and opportunities for innovation; key elements in delivering infrastructure projects at speed.

It remains to be seen how the Government will fully reconcile its commitment to significant infrastructure investment with net zero commitments but, as things stand, there is significant political momentum behind delivering infrastructure schemes quickly. Providers will need to ensure that they are well placed to compete for opportunities as they arise, especially given the change in advertising requirements for public contracts since Brexit (by which the Find a Tender Service replaced the OJEU) and in light of the significant changes to procurement legislation that are anticipated within the next 12 months.

Publications & Guidance

Plan, prevent and respond: reforming health security 
Department of Health and Social Care | 24 March 2021
Secretary of State for Health and Social Care Matt Hancock spoke at the Local Government Association Annual Public Health Conference 2021. He spoke about upcoming reforms, focusing on health security. He covered the creation of the UK Health Security Authority, launching on 1 April, and the introduction of Integrated Care Systems in the Health and Care Bill.

Full policy paper: Transforming the public health system: reforming the public health system for the challenges of our times

Local authority data: finances
House of Commons Library | 15 March 2021
This page provides details on both funding and spending of local authorities in England.


'Digital twin' of Bradford city centre to be created
LocalGov | 12 April 2021
A new project to virtually ‘clone’ Bradford city centre has been unveiled. Virtual Bradford will revolutionise how the council deals with planning, air pollution and traffic management. It will also allow the creation of heritage trails, virtual shops and virtual exhibitions.

The project - a collaboration between Bradford Council and the University of Bradford - will create a ‘brick for brick’ hi-resolution copy of the city centre.

First legal challenge launched against ‘pork barrel’ levelling up fund | Local Government Chronicle (LGC) (lgcplus.com)
Local Government Chronicle | 6 April 2021
The first step has been taken in legal proceedings against the government over the criteria it used to prioritise areas for the £4.8bn levelling up fund.

Appetite for PWLB borrowing returns in March | Public Finance
Public Finance | 1 April 2021
Local authorities in England borrowed £856m from the Public Works Loan Board last month, as councils refocus on capital projects following a lull due to Covid-19.

Councils are failing to maximise the value of their surplus assets | Local Government Chronicle (LGC) (lgcplus.com)
Local Government Chronicle | 31 March 2021
Six steps can help local authorities realise the financial and environmental benefits of using online marketplaces to dispose of surplus assets. 

Croydon chiefs question section 114 notices | Public Finance
Public Finance | 26 March 2021
Section 114 notices are unfit for purpose, two senior officers at the London Borough of Croydon – which issued two last year due to financial problems – told MPs this week.

BCP Council to pilot drones in fight against litter
LocalGov | 26 March 2021
Bournemouth, Christchurch and Poole Council has announced a pilot scheme which will see drone-based technology used to tackle the issue of litter. The trial, which will be carried out this summer in partnership with the environmental charity Hubbub and McDonald’s, will see intelligence gathered from drone data to inform the future placement of bins, street cleansing schedules and campaigns to encourage visitors to dispose of litter responsibly.

Mayor of Greater Manchester makes landmark decision: city-region to be first outside London to have local control over buses
Greater Manchester Combined Authority | 25 March 2021
Greater Manchester will be the first city-region outside London to have buses that are under local control, allowing local leaders to set routes, frequencies, fares and tickets. By the end of 2025, this will allow Greater Manchester Combined Authority (GMCA) to fully integrate buses with the rest of the transport network, as part of a passenger-focused network with easy end-to-end journeys.

Franchising will also support GMCA’s objectives as set out in the Greater Manchester Strategy to become the best place in the world to grow up, get on and grow old. With buses under local control, Greater Manchester leaders will be able to connect people by public transport to work, home, education, culture and leisure.  Bus franchising also means GMCA can set environmental standards for a cleaner, greener bus fleet, helping to meet the city-region’s targets to tackle the climate emergency, reduce harmful emissions and clean up our air.

A further press report can be found here: Burnham takes back control with bus franchising

This decision is subject to a legal challenge, details of which can be found here; Combined authority franchising announcement a ‘surprise’ | Public Finance

East Midlands councils launch development corporation
LocalGov | 24 March 2021
A consortium of local authorities in the East Midlands is taking a major step forwards with proposals to launch a body which could trial a new model for planning and cross-regional economic development. Leicestershire and Nottinghamshire County Councils, Broxtowe and Rushcliffe Borough Councils and North West Leicestershire District Council are jointly funding an interim vehicle which will begin the work of the proposed East Midlands Development Corporation.

The interim vehicle, which will commence work in the next few weeks, is expected to build capacity for a new kind of locally-led urban development corporation, assuming responsibility for activities such as masterplanning, site enabling works and marketing to potential investors and developers.

Councils to be given five years to spend Right to Buy receipts
LocalGov | 22 March 2021
The Ministry of Housing, Communities and Local Government belatedly published its response to a 2018 consultation on Right to Buy. In a letter sent to council chief executives and leaders at authorities with housing stock, Mr Jenrick said he had listened to authorities concerned about the short period of time in which they must spend RtB receipts, which had been just three years.

BoE ‘not out of firepower’ as governor discusses negative interest rates | Public Finance
Public Finance | 16 March 2021
The Bank of England is looking at “new tools” to guide the UK economy out of the crisis caused by Covid-19, according to governor Andrew Bailey.

Income losses drive 11% jump in net council expenditure
Public Finance | 11 March 2021
Total local authority spending in the first three quarters of 2021-22 was £77.9bn, £7.9bn higher than in April-December last year, according to local authority outturn data published today.

The rise was partly fuelled by an 89% increase in net spending on economic affairs, which includes transport and maintenance services, to £6.1bn up from £3.2bn in the previous year. An official release from the department said this was mainly due to “lower public transport fare income, most notably by Transport for London and other lost income including parking charges.”

News analysis: CIFPA code revisions
Public Finance | 9 March 2021
Tightened wording aims to further restrict councils’ ability to borrow money for commercial property investments aimed at raising revenue.

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Place & Growth

Service charges – who decides what is fair?

Service charge clauses in leases are commonly drafted so that the tenant will pay a “fair proportion” of the cost of services provided to a multi-occupied building, shopping centre or estate.  But when the tenant disagrees about the share of service charge being demanded, who has the last word on whether the landlord’s assessment is fair?

This situation was considered in the recent High Court case of Criterion Buildings Ltd v McKinsey and Company Inc United Kingdom and another [2021] EWHC 216 (Ch).


McKinsey was the tenant of offices in part of the Criterion Building in Piccadilly Circus. Under the service charge provisions in the lease McKinsey had covenanted to pay a “due proportion” of the total cost of the services and expenses specified.  This proportion was defined as “a fair proportion to be determined from time to time by the landlord taking into account the benefit that was derived”.

Disputes arose between McKinsey and its landlord Criterion over the proportion of the service charge allocated to them.  By 2019, the arrears of service charge had reached £2.2m plus interest and Criterion sued for the amount due.

McKinsey objected to the claim by raising two main issues:

  1. Whether Criterion had apportioned the service charges due between the various tenants of the building in accordance with the provisions in the lease. McKinsey’s case was that the “due proportion” of costs charged did not comply with the lease because it was not “fair” when assessed on an objective standard.
  2. Whether Criterion had properly operated the sinking/reserve fund provisions in the lease. McKinsey argued that some payments charged by the landlord as contributions to a sinking fund were not contractually due as they were being used to fund routine service charge costs.
The decision

On the facts, the High Court found in favour of Criterion and held that McKinsey’s objections failed on the points it had raised:

  1. The court held that when apportioning service charge between tenants, the decision as to what constitutes a “fair proportion” is one for the landlord to make rather than the court. It is for the tenant to establish (and not the landlord) that it has been charged more than a “due proportion” of the service costs.  It was also acceptable for the landlord to make a subjective decision in relation to apportioning the charges subject to that decision being rational.
  2. Sinking/reserve fund. The lease specified that Criterion was permitted to demand an amount “it reasonably determines is appropriate to build up and maintain” the relevant fund. McKinsey had not shown that Criterion had made unreasonable decisions as the service charge contributions to sinking funds were to be spent during the following years. 
Some practical points

This is a helpful decision for landlords as it confirms that provided a landlord acts with rationality, it has the ability to determine apportionments and it is for the tenant to prove otherwise.

An interesting point made by the judge was in relation to the claim by the tenant that the decision should be an objective one.  He commented that the proportion of the service charge payable by each tenant made no financial difference to the landlord (the landlord has “no axe to grind”) so on that basis, the landlord is able to make a subjective decision about the percentage.

However, it is advisable for landlords to keep evidence of how they calculate the apportionments of service charge in case they are challenged at a later date.

For tenants, it is a reminder that they should check the service charge clauses carefully so they are aware of how the charge is apportioned and also understand the landlord’s methodology for calculating this.  Unless the tenant can prove its landlord’s decision is irrational then they will be bound by it and the courts will not interfere.


The Non-Domestic Rating (Designated Area) Regulations 2021
SI 2021/404. These Regulations designate an area in England (“designated area”) for the purpose of paragraph 39(1) of Schedule 7B to the Local Government Finance Act 1988 (“the 1988 Act”) (local retention of non-domestic rates). They provide rules for calculating in respect of the billing authority in England all or part of whose area falls within the designated area:

  • the billing authority’s non-domestic rating income in respect of the designated area for a specified year, and
  • the proportion of that non-domestic rating income that is to be disregarded for the purpose of specified calculations under Schedule 7B to the 1988 Act.

The Community Infrastructure Levy (Amendment) (England) Regulations 2021
SI 2021/337. The Community Infrastructure Levy Regulations 2010 (“The 2010 Regulations”) provide for the imposition of a charge known as the Community Infrastructure Levy (“CIL”). This instrument amends the date in regulation 60(7A) of the 2010 Regulations so that for “31st March 2033” there is substituted a new date of “31st March 2043”. This extends the period of time within which the Mayor of London can collect and apply CIL to borrowing for the Crossrail project.

The Town and Country Planning (General Permitted Development etc.) (England) (Amendment) Order 2021
SI 2021/428. This Order amends, primarily, the Town and Country Planning (General Permitted Development) (England) Order 2015 (“the GPDO”). The GPDO provides, for the purposes of section 59 of the Town and Country Planning Act 1990 (c. 8), for the granting of permission for certain classes of development without the requirement for a planning application to be made under Part 3 of that Act.

Home Office brings in unlimited fines for breaches of fire safety regulations
Inside Housing | 17 March 2021
Building owners who breach fire safety regulations under the Fire Safety Order will be subject to unlimited fines, the Home Office has announced. The measures come as part of the government’s response to the Fire Safety Consultation and will be included in the Building Safety Bill legislation currently working its way through parliament.

It comes amid widespread reforms of building safety legislation in the country. The government’s draft Building Safety Bill, published last summer, proposes a number of changes, including the creation of a Building Safety Regulator, a new Homes Ombudsman and an accountable person for every high-rise building in the country.

Publications & Guidance

Coronavirus (COVID-19): Organised events guidance for local authorities
Department for Digital, Culture, Media and Sport | 6 April 2021
This guidance is aimed at local authorities in England. It is designed to assist local authorities in ensuring that events are able to go ahead safely, in accordance with what is permitted at each step of the Roadmap out of lockdown.

Fresh wave of grant funding launched as councils are called on to do their bit to continue supporting businesses
Department of Business, Energy and Industrial Strategy | 1 April 2021
From today, businesses in England in the non-essential retail sector will be eligible for one-off grants of up to £6,000, while businesses in the hospitality, accommodation, leisure, personal care and gym sectors, which are reopening later, will be eligible for one-off grants of up to £18,000. The £5bn of government funding available through the Restart Grants scheme will be delivered by local authorities.

The letter regarding the distribution of grant funding: Letter to all Local Authorities from Ministers Scully and Huddleston

Government response to the local housing need proposals in “Changes to the current planning system”
Ministry of Housing Communities and Local Government | 1 April 2021
The government has responded to the consultation on changing the standard method for assessing local housing need. The government will not proceed with the specific changes to the standard method that was consulted on, as the response stressed that the distribution of need was not right, with too much strain being put on rural areas and not enough focus on the renewal of towns and cities, which risked protected landscape and Green Belts. Instead, the government will retain the standard method in its current form, but will apply a 35% uplift to the post-cap number generated by the standard method in Greater London and to the local authorities with contain the largest proportion of the other 19 most populated cities and urban centres in England.

The Housing Secretary has also announced changes to planning regulations that came into force on 31 March 2021: New freedoms to support high streets and fast track delivery of schools and hospitals across England introduced today

Business rates relief boosted with new £1.5bn pot
HM Treasury | 25 March 2021
Ministers have today set out plans to provide an extra, targeted support package for businesses who have been unable to benefit from the existing £16bn business rates relief for retail, hospitality and leisure businesses. Retail, hospitality and leisure businesses have not been paying any rates during the pandemic, as part of a 15 month-long relief which runs to the end of June this year.

The £1.5bn pot will be allocated to local authorities based on the stock of properties in the area whose sectors have been affected by COVID-19. Local Authorities will use their knowledge of local businesses and the local economy to make awards.

A House of Commons Library briefing can be found here: Budget 2021: Additional business rate reliefs in England (parliament.uk)

Housing Ombudsman sets out new framework on systemic issues
Housing Ombudsman | 24 March 2021
The framework will enable the Ombudsman to examine and respond to issues and themes that arise in the sector. The complaints they handle each year will provide the basis for identifying potential issues, together with other indicators from regular research and relevant external information.

The framework will aim to identify:

  • failures in complaint handling, where further work could support earlier resolution of disputes
  • service failures, where further investigation into underpinning policies, procedures or approach could prevent service failure reoccurrence
  • reoccurring issues across several landlords where further investigation could promote greater understanding and sharing of best practice.

Local transport update: national bus strategy for England published
Department for Transport | 15 March 2021
In this written letter to Parliament, Transport Minister Grant Shapps outlines the national bus strategy for England outside of London. This includes the aim that every local transport authority and bus operator in England will be in a statutory enhanced partnership or a franchising arrangement, and a commitment to consult on ending the sale of new diesel buses into order to develop a zero-emission bus fleet.  The full report can be found here.

Extra funding for local transport authorities to roll out zero-emission buses in England was also announced at the end of March: Multi-million pound scheme for zero-emission buses across England launched


Wirral Council launches Birkenhead regeneration plan (acenet.co.uk)
ACE | 29 March 2021
The Association for Consultancy and Engineering (ACE) has announced the publication of the Birkenhead Framework 2040 by Wirral Council. The framework aims to create more family-friendly neighbourhoods, with development plans for new homes, a linear park and a network of green cycling and pedestrian routes. Over 900,000sqm of commercial space is planned in key locations, including offices, a market and town square, to reinvigorate the local economy. To this end, £24.6m has been secured from the Future High Streets Fund.

Traffic wars: who will win the battle for city streets? | Road transport
The Guardian | 25 March 2021
Radical new plans to reduce traffic and limit our dependence on cars have sparked bitter conflict. As legal challenges escalate, will Britain’s great traffic experiment be shut down before we have time to see the benefits?

Launch of new independent rough sleeping commission
LocalGov | 24 March 2021
A new independent commission to learn the lessons from how rough sleepers were supported during the pandemic has been launched. Chaired by Lord Bob Kerslake, the Commission on Homelessness and Rough Sleeping will aim to understand what worked during the pandemic and what is now needed to embed the good practice.

MPs launch inquiry into controversial permitted development rights
LocalGov | 24 March 2021
The Housing, Communities and Local Government Committee has launched a new inquiry to examine the Government’s approach to permitted development rights (PDRs).

In recent years, the Government has expanded the use of PDRs. In 2020, they legislated to permit conversion between a much wider range of commercial and retail premises, and created new PDRs to allow unused office buildings to be converted into residential property. The new legislation also gave homeowners the right to add additional stories to existing post-war homes.

Over 50,000 households to get warmer, greener homes in £562m boost
Department for Business, Industry and Skills | 23 March 2021
The £562m government funding will enable over 200 local authorities across England and Scotland to fund a nationwide upgrade of the UK’s least energy efficient and fuel-poor homes. This will help to transform over 50,000 low-income households and social housing properties and support over 8,000 energy sector jobs annually, including local plumbers, builders and tradespeople.

These schemes consist of the £500m Local Authority Delivery (LAD) Fund, a component of the Green Homes Grant, that will help households with an income of under £30,000 in England save hundreds of pounds each year by making them better insulated. A further £62m Social Housing Decarbonisation Fund Demonstrator, which will explore innovative ways to deliver deep retrofits of social housing, will help to bring down the cost so it can be scaled up and rolled out on homes across the UK in the years ahead.

A list of authorities awarded funding for the LAD

The Environmental Audit Committee has called for more money to be released earlier under the Social Housing Decarbonisation Fund, and for housing associations to be allowed to lead bids.

Boris Johnson’s 'levelling up' plans unlikely to succeed, says watchdog | Economics | The Guardian
The Guardian | 23 March 2021
A government watchdog led by the Bank of England’s chief economist has said Boris Johnson’s plans for “levelling up” Britain are unlikely to succeed because they rely too heavily on infrastructure spending and one-off funding schemes controlled from Westminster.

Pouring cold water on the prime minister’s election promise to rebalance Britain’s regionally lopsided economy, the Industrial Strategy Council (ISC) said the levelling-up agenda risked failure even though its ambitions were vague and would struggle to stand up to scrutiny.

Full report

RSH ‘keen to strengthen links’ with council housing departments ahead of white paper changes
Inside Housing | 17 March 2021
Fiona MacGregor, chief executive of the Regulator of Social Housing, wrote to councils yesterday reminding them of reforms signalled by ministers in the Social Housing White Paper that was published in November.

A central plank of the government’s response to the Grenfell Tower fire, the white paper laid out plans to move back to a proactive system of regulating consumer standards in the social housing sector, with landlords subject to regular inspections and assessment against tenant satisfaction data.

Councils are not yet subject to proactive engagement with the RSH, unlike housing associations which are routinely checked against the regulator’s governance and financial viability standards.

Mayor plans for 1,500 affordable homes on Dagenham car plant site | London City Hall
London City Hall | 16 March 2021
The Mayor of London, Sadiq Khan, today announced a landmark deal to secure more than 1,550 genuinely affordable homes on the former Dagenham Stamping Plant car works site in East London.

The deal, which involves an £80m grant from the Mayor’s Affordable Housing Programme, has enabled Peabody housing association to acquire the 45-acre site.  The mixed-tenure development will provide homes at London Affordable Rent and for Shared Ownership

Council launches rights and standards charter for exempt accommodation residents
Inside Housing | 15 March 2021
Birmingham City Council has launched a charter of rights and a set of standards for exempt accommodation residents, placing new requirements on providers and managing agents.

The Charter of Rights, developed alongside Spring Housing Association, is intended to make tenants and their families aware of the service they should expect from their landlord.

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Governance & Reorganisation

Remote meetings – what next?

It will have come as a bit of a blow for some council leaders to receive the letter from Luke Hall MP, Minister for Local Government, at the end March announcing that the Government would not be extending regulations to allow remote meetings to continue after 6 May 2021. This is despite the ‘commendable efforts’ of all councillors and officers in supporting their communities and ensuring vital business continued during these unprecedented times, the fact that remote meetings have proved to be a resounding success and that councils are now likely to face significant challenges having to source alternate venues in order to be able to host meetings with social distancing measures in place.

Unsurprisingly the news was not well received. The Local Government Association said the decision was ‘extremely disappointing’, noting that MPs will retain the right to participate remotely until at least 21 June 2021. Readers will be aware that Lawyers in Local Government (LLG), the Association of Democratic Services (ASDO) and Hertfordshire County Council have made an application to the High Court for a declaration (not a ‘legal challenge’ as reported incorrectly in the media) that councils already had the powers needed to hold online/remote meetings. The hearing took place on 21 April 2021 and a decision is expected swiftly, given the urgency with the current regulations due to expire.  

The Government has since come out in support of the case, with Secretary of State Robert Jenrick stating “there is a case to be heard…as the legislation was passed at a time when virtual meetings could not have been envisaged”.  It is worth noting however that the Government’s own previous consultation paper on remote meetings stated that meetings required decision makers to be physically present at a meeting under the Local Government Act 1972.

As a contingency, perhaps there is relief to be found in Part 1 of the Local Government Act 1999 (LGA 1999) – s.16 provides the Secretary of State with power to make an order that modifies or excludes the application of an enactment where they think that the enactment prevents or obstructs compliance by best value authorities with the requirements of Part 1. Not being able to undertake remote meetings could be just this, however this is not a complete solution given that not all of those bodies presently able to hold remote meetings under the regulations are ‘best value authorities’ (although there is some scope to extend the definition).

So what if the High Court does not find in favour of pre-existing powers for remote/hybrid meetings? There are a number of options available as an alternative to reverting back to full physical attendance, some of which will require undertaking appropriate risk assessments, and complying with various government and Health and Safety Executive guidance:

  • For councils operating under executive governance, all executive powers vest in the Leader who can take all executive decisions, or delegate those decisions to other executive members or officers. In other words, there is no need for meetings of the executive to be held at all
  • Virtual quasi meetings with officer decisions following members giving an ‘in principle’ decision – but officers would have to be delegated full powers to deal with everything that the relevant committees could decide
  • Reduced member attendance by reducing the size of committees – with appropriate agreement between political groups (and it may be necessary to have “reserves” on stand-by)
  • Hybrid meetings based on selected politically balanced councillors reaching the quorum in the room, with risk assessments and social distancing, and other members attending virtually to provide their views and indicate how they would vote
  • Officer decision making – but again, officers would have to be delegated full powers to deal with everything that the relevant committees could decide.

It is of course important to note that certain functions are non-delegable (e.g. approving the budget or plans in the policy framework, approving political balance and sizes of committees or appointing the Head of Paid Service etc) although one of the other options above could be adopted to facilitate decisions on these functions.  

Councils should also be mindful that s.85 of the Local Government Act 1972 operates to vacate the office of any member who has failed to attend any meeting of the council for a period of six consecutive months, unless that failure to attend is for a reason approved by the council before the expiry of that period. This may be relevant should a council seek to implement one of the options above.

In the meantime, the government has launched its call for evidence on remote meetings, which closes on 17 June 2021, and has updated its guidance on the safe use of council buildings to reflect this changing legislation.

Publications & Guidance

Addendum to the West Yorkshire devolution deal
Ministry of Housing, Communities and Local Government | 26 March 2021
The West Yorkshire devolution deal was agreed and announced by the Chancellor on 11 March 2020. On 29 January 2021, the West Yorkshire Combined Authority (Election of Mayor and Functions) Order 2021 was signed by Minister Luke Hall and came into force on 1 February 2021.

This Order, to which all the five West Yorkshire local authorities and the West Yorkshire Combined Authority have consented, implements the previously agreed devolution deal with modifications to the infrastructure tariff, planning powers and Police and Crime Commissioner functions.

Levelling Up Fund: documents
Ministry of Housing, Communities and Local Government | 26 March 2021
The government has published the methodology for awarding funds, the application form, the technical note and the privacy note.

The LUF methodological note sets out the process and rationale behind the index of priority places for the Levelling Up Fund. The technical note provides information on who can apply, what the Fund can support and the role of bidding authorities. The note also describes the assessment process that will be used by the UK government to assess applications put forward by bidding authorities across Great Britain and Northern Ireland. The application deadline is noon on Friday 18 June 2021.

The Good Law Project has sent a pre-action letter to the Secretary of State over the allocation of local authorities to different categories: Good Law Project sends pre-action letter to Secretary of State over allocation of 'Levelling Up Fund'

Security guidance for May 2021 elections 
Cabinet Office | 26 March 2021
For these upcoming May 2021 elections, as with any election, there are a number of security considerations that need to be made both by those planning and those running for the elections.

This collection of guidance provides advice on good security practice for candidates and those in local authorities. Much of this advice will be relevant all year round. In particular, there is guidance for local authorities from the National Cyber Security Centre: Election guidance for local authorities - NCSC.GOV.UK

Indemnity for Returning Officers at Local Elections in England
Cabinet Office | 25 March 2021
The Cabinet Office will provide a specific and limited indemnity to Returning Officers and Counting Officers at forthcoming local government elections and referendums in England taking place between 6 May 2021 and 4 May 2022 (both dates inclusive). The indemnity covers, subject to exclusions, Returning Officers and Counting Officers in respect of losses, liabilities, damages, costs, and/or reasonable expenses in claims that may be made against or incurred by the Returning Officer or Counting Officer in relation to COVID-19.

The Government’s approach to elections and referendums during COVID-19: additional information for electoral administrators, candidates, campaigners and voters
Cabinet Office | 25 March 2021
The information set out in this guidance is designed to assist preparations by electoral administrators, candidates, campaigners and voters by providing details on some of the commonly asked questions surrounding the May 2021 polls being held in England.

COVID-19: Letter to council leaders on the future of remote meetings
Ministry of Housing, Communities and Local Government | 25 March 2021
Letter from the Minister for Local Government to the leaders of all principal councils in England on the future of regulations introduced during the coronavirus pandemic regarding remote meetings, confirming that The Local Authorities and Police and Crime Panels (Coronavirus) (Flexibility of Local Authority and Police and Crime Panel Meetings) (England and Wales) Regulations 2020 do not apply to meetings on or after 7 May 2021. This is due to the logistical difficulties in bringing forward emergency legislation to extend the provisions.

The government has also launched a call for evidence on remote meetings, which closes on 17 June 2021, and updated its guidance on the safe use of council buildings to reflect this changing legislation.

The decision is already facing a legal challenge from Hertfordshire County Council, which has been directed by a hearing at the High Court to be resolved by the end of April. This is a move that has been supported by the government: Jenrick supports push for virtual meetings to continue after May | Public Finance.

Secretary of State statement: Liverpool City Council
Ministry of Housing, Communities and Local Government | 24 March 2021
The Secretary of State outlines the findings of the Best Value Inspection report that was published on 24 March, commissioned following a Merseyside Police investigation into Liverpool City Council that concluded with arrests on suspicion of fraud, bribery and abuse of public office. He then goes on to outline the response of the government, under the Local Government Act 1999, which includes appointing Commissioners to carry out limited functions of the council for at least the next three years. Whole council elections will be held in 2023.

The full intervention package is outlined in the Secretary of State’s letter to the Chief Executive of Liverpool Council.

The government published full details of the initial inspection and proposed intervention on 6 April.

You can view press coverage of the government’s response to the report on the BBC, LocalGov and The Independent.

Plan, prevent and respond: reforming health security
Department of Health and Social Care | 24 March 2021
Secretary of State for Health and Social Care Matt Hancock spoke at the Local Government Association Annual Public Health Conference 2021. He spoke about upcoming reforms, focusing on health security. He covered the creation of the UK Health Security Authority, launching on 1st April, and the introduction of Integrated Care Systems in the Health and Care Bill.

Full policy paper: Transforming the public health system: reforming the public health system for the challenges of our times

Public health ring-fenced grant 2021 to 2022: local authority circular
Department of Health & Social Care | 16 March 2021
In 2021 to 2022 the total public health grant to local authorities will be £3.324bn. The grant will be ring-fenced for use on public health functions. This may include public health challenges arising directly or indirectly from coronavirus (COVID-19).

The Secretary of State has determined, pursuant to Section 31 of the Local Government Act 2003, to pay grants to relevant authorities in the amounts indicated for the financial year 2021 to 2022. 


County council chiefs welcome new Northamptonshire authorities
LocalGov | 1 April 2021
County council leaders have welcomed two new unitary authorities which officially came into existence today in Northamptonshire. The replacement of the county and district authorities with West Northamptonshire and North Northamptonshire councils will require an investment of £43.5m.

Mental health recovery plan backed by £500m
Department of Health and Social Care | 27 March 2021
£15m to help level up mental health and wellbeing across the country through funding initiatives to promote positive mental health in the most deprived local authority areas in England - eligible local authorities will receive around £500,000 each to fund prevention activities like debt advice, carers support, outreach to people facing loneliness and isolation, youth projects and community groups for those most affected by Covid-19 including minority ethnic communities.

Croydon council ends section 114 thanks to £120m bailout
LocalGov | 26 March 2021
The cash-strapped council issued a Section 114 notice last November which meant that all expenditure went through a regular spending control panel and non-essential spend was stopped.

A non-statutory review in February found failures in identifying, escalating and addressing financial risk at the council. It also highlighted poorly managed commercial ventures and low levels of reserves, which caused significant issues.

Government opts to retain legacy public pension calculations
Public Finance | 24 March 2021
A government consultation was launched in 2016 after reforms saw public pension funds make a dedicated calculation for the full cost of yearly changes in legacy guaranteed minimum pension requirements.

In response to the consultation, published yesterday, the Treasury opted to make this measure permanent, rejecting an alternative organisational approach which would have merged GMP liabilities into regular scheme payments.

East Midlands councils launch development corporation
LocalGov | 24 March 2021
A consortium of local authorities in the East Midlands is taking a major step forwards with proposals to launch a body which could trial a new model for planning and cross-regional economic development.

Leicestershire and Nottinghamshire County Councils, Broxtowe and Rushcliffe Borough Councils and North West Leicestershire District Council are jointly funding an interim vehicle which will begin the work of the proposed East Midlands Development Corporation.

The interim vehicle, which will commence work in the next few weeks, is expected to build capacity for a new kind of locally-led urban development corporation, assuming responsibility for activities such as master planning, site enabling works and marketing to potential investors and developers.

Five councils secure £100m in SEND bailout deals
Local Government Chronicle | 22 March 2021
Five councils have clinched deals with the Department for Education providing them with almost £100m to cover their long standing special educational needs and disability (SEND) deficits, with more councils potentially also in the pipeline for similar support packages.

DfE has said it will cover historic Send deficits for Stoke on Trent City Council, Richmond upon Thames, Kingston Upon Thames and Hammersmith & Fulham LBCs and Bury MBC, which are facing exceptionally high dedicated school grant (DSG) deficits. In return, these councils have agreed to make reforms to their SEND services and meet strict savings targets.

'Welcome back' fund launched for high streets and coastal areas
LocalGov | 22 March 2021
Councils will receive £56m to help high streets and seaside resorts open safely this summer. The new Welcome Back Fund can be used to install signage and floor markings, invest in street planting and seating areas, run publicity campaigns and prepare to hold events.

Communities secretary, Robert Jenrick, also said the first 70 councils to benefit from support from the High Streets Task Force have been selected.

An analysis of current trends in town centres can be found here: Evidence briefing: improving high streets and town centres | What Works Centre for Local Economic Growth

Ministers vow £45m fund for safer streets including lighting and CCTV
Metro | 15 March 2021
In a bid to improve security at night, the Government’s Crime and Justice Taskforce meeting today said it would double the Safer Streets fund to £45m. The funding will provide better lighting and CCTV facilities in the streets so women are safer walking through parks and streets on their way home.

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Contract Management

Exclusion clauses – new case on the enforceability of exclusion clauses in online terms and conditions

Green v Petfre (Gibraltar) Ltd t/a Betfred [2021] EWHC 842 (QB)

The High Court has recently granted summary judgement in relation to a case of an individual who was seeking to recover substantial winnings (over £1.7m) from an online betting company. 

The claimant had been playing a betting game via an online platform and on finishing the game the screen showed betting chips to the value of £1,722,500.24.  When he tried to withdraw the winnings into the registered cash account, he was not able to do so.  The claimant issued a claim relying on terms and conditions included in a click-wrap licence a number of years previously, in particular one clause that stated “Customers may withdraw funds from their account at any time providing all payments have been confirmed”.

Betfred sought to rely on various exclusion clauses in industry standard online terms and conditions to avoid liability and to avoid paying out the claimant’s winnings.  They argued that the winnings were the result of a software defect or glitch in the game and they did not need to pay out.  Betfred highlighted that the terms of the contracts (general terms of use, EULA and individual game rules) excluded liability where a pay-out had been triggered by a software malfunction or defect.   

Betfred had also argued that the claim to recover the winnings was unsuitable for summary judgement– primarily because of the use of the standard industry terms and because it claimed that further evidence was needed to determine the issues.

The judge held that the claim was suitable for summary judgement, despite the potential impact on the wider industry and that she had sufficient evidence.  She ordered Betfred to pay the claimant his winnings.

In particular the judge commented that the:

  • wording of the clauses relied on was inadequate
  • wording was different to wording used elsewhere in the documents to reserve the right to void bets and it didn’t deal with failures to pay out winnings or undetectable glitches
  • documentation was very long, complex and obscure and it’s appearance did not make it appropriate to determine the rights and duties of the parties in this type of contract
  • use of the word “malfunction” in the terms did not seem to cover these circumstances i.e. where the game seemed to be functioning but produced a set of odds that were unintended. Instead it seems to relate to a visible or obvious failure (e.g. internet failure).

Overall the judge concluded that the arguments that Betfred put forward in relation to the exclusion clauses needed a strained and unnatural meaning to be given to the terms. 

Further the way the clauses were presented and the failure to draw the exclusions to the consumer’s attention also meant that the exclusions were not incorporated in the contract, even if they had been effective to exclude liability.

Whilst the decision is specific to the facts in that case, it is useful as guidance on the pitfalls of drafting exclusions of liability in consumer website contracts.  In particular in relation to criticisms of the drafting of the terms and conditions, such as the terminology, lay out and overuse of defined terms, as well as highlighting the dangers of inadequate signposting of significant exclusions to online consumers. 


“Don’t go off the rails…” – A case law update (Bechtel Limited v High Speed Two (HS2) Limited)
Lawyers in Local Government | 10 March 2021
A short summary of some of the key "takeaways" for local authorities from the most recent high profile procurement litigation, featuring the HS2 project. 

Publications & Guidance

Pre-paid card firms supplying councils acted ‘as a cartel’, regulator says
LocalGov | 1 April 2021
Three out of five firms that issue councils with pre-paid cards have admitted to breaching competition rules and agreed to pay maximum penalties totalling over £32m. The Payment Systems Regulator (PSR) has alleged that Mastercard, allpay, APS, PFS and Sulion engaged in anti-competitive behaviour by agreeing not to poach each other’s clients.

Update on procurement policy notes published by the Welsh Government and UK government | GOV.WALES
Welsh Government | 24 March 2021
The Welsh Government has recently published a new Welsh procurement policy note (WPPN) and adopted procurement policy notes (PPN) from the UK government.

Vital public services including schools and hospitals “face serious disruptions” as Private Finance Initiative ends
UK Parliament Committees | 19 March 2021
Since the 1990s successive governments have used the Private Finance Initiative (PFI) to build and run more than 700 public infrastructure assets including roads, schools and hospitals. These contracts between the private sector and public bodies are now coming to an end. In its report published today the Public Accounts Committee warns that government’s lack of preparation for this massive transfer of public assets, combined with insufficient data and skills, could lead to the contracts ending in disruption to vital public services, and added costs.

Read the report summary, or the full report


Combined authority franchising announcement a ‘surprise’ 
Public Finance | 26 March 2021
The Greater Manchester Combined Authority’s decision to press ahead with a £135m franchising plan is premature, according operators bringing a legal challenge. Plans were approved yesterday for the GMCA to become the first authority outside London to introduce a franchise agreement, following almost three decades of privatisation. The announcement however came after Stagecoach and Rotala launched a judicial review into the GMCA's consultation on its plans earlier this month – a review set to be heard in late May.

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Disputes & Regulatory Support

COVID passports and implications for councils

The Government has confirmed that a COVID-status certification system (COVID passports) will be developed over the coming months with the aim of showing vaccination, test or immunity status of the holder. This system could allow high-risk settings to be opened up more safely and with more people. However, the establishment of such a system may have a significant logistical and cost implication for councils.

Responding to Boris Johnson's announcement of the next step of the roadmap out of lockdown, Cllr James Jamieson, Chairman of the Local Government Association, said: "We urge Government to work closely with local government on any proposals for Covid-19 status certification. They are likely to bring significant implications for councils, particularly with regards to licensing, enforcement and support to venues and businesses who would have to use them. Councils can therefore provide vital insight into how the scheme can work best in practice, consider equalities implications and links to vaccine confidence.”

There are also fears following the Equality and Human Rights Commission’s (EHRC) warning that COVID passports could be discriminatory against marginalised groups, whose vaccine take-up is lower than average, noting that the system could create a “two-tier society”. The EHRC has said if COVID passports are introduced they must be time limited and regularly reviewed by Parliament to ensure they are proportionate and reflect the progress of the vaccine rollout. Further, those who cannot take the vaccine must have easy access to exemption documentation.

With these concerns in mind, local leaders are calling on the government to work closely alongside local authorities to use their knowledge and connections within local communities when developing and establishing any sort of system. Cllr James Jamieson emphasised that "while we all look forward with huge hope of a return to our normal way of life, the responsibility is on us all to test ourselves regularly, share our contacts on request and self-isolate when required to keep case rates as low as possible."

The Cabinet Office is currently undertaking a review on the proposed introduction of vaccine passports having undertaken a two-week consultation in March 2021; the outcome of that review is awaited.


Too much, too soon
Landmark Chambers | 6 April 2021
In Ibrahim v Haringey LBC, Mr Justice Lane allowed an appeal against a decision of a Circuit Judge to dismiss a claim that an asylum seeker who had been accommodated by a local authority under the “Everyone In” scheme did not have an arguable case that he had been granted a secure tenancy.

The course adopted by the judge had been procedurally unfair. The parties had attended the return date expecting to deal only with whether the injunction should continue; the judge had been wrong to deal with the underlying claim as well. Moreover, the judge had gone too far in making the findings that he had made. There was an issue of law as two which power had been used to provide accommodation, which could not be decided summarily at an interim injunction hearing and should go to full trial.

The full decision: Ibrahim v London Borough of Haringey & Anor [2021] EWHC 731 (QB)

Claimant wins housing case against council in part but judge rejects anonymity bid
Local Government Lawyer | 31 March 2021
Ruba Imam went to the High Court for judicial review of Croydon’s failure to provide her with suitable accommodation under section 193(2) of the Housing Act 1996. Croydon admitted breach of its statutory duty because the accommodation provided was not suitable. The two sides though disputed the relief required. Ms Imam sought a mandatory order requiring Croydon to provide suitable accommodation. She also raised alleged breaches of the Equality Act 2010 and an allegation of unlawfully failing to determine her request to be given Band 1 priority under Croydon’s housing allocation scheme.

Mathew Gullick QC, sitting as a deputy judge of the High Court, rejected the claim that Croydon was in breach of the public sector equality duty noting Ms Imam had received priority over non-disabled housing applicants. He said that although Croydon was in breach of its statutory duty, he would not make a mandatory order as he accepted there was “a spectrum of seriousness” in terms of possible breaches.

The full decision: Imam, R (On the Application Of) v The London Borough of Croydon [2021] EWHC 736 (Admin)

Court of Appeal hands down ruling in housing case on where authorities issue late reviews
Local Government Lawyer | 25 March 2021
The Court of Appeal has ruled on two points of law that arose over a case where an applicant first wished to establish a local connection with Milton Keynes but later did not.

He said the case raised two points of law. The first was where an applicant who is dissatisfied with a decision made pursuant to s.184 of the Housing Act 1996 requests a review of that decision pursuant to s.202 of the Act, what is the legal status of the requested decision if the authority issues and notifies the applicant of the review decision outside the time specified by applicable regulations?

The second was where a review decision has been issued and notified to the applicant late, is it open to the applicant to commence an appeal to the County Court against the original s.184 Decision relying upon the terms of s.204(1)(b) of the Housing Act 1996?

The full judgment: Ngnoguem v Milton Keynes Council [2021] EWCA Civ 396

Care workers lose 'sleep-in shift' court challenge - BBC News
BBC News | 19 March 2021
The Supreme Court has dismissed the appeals of overnight care workers Claire Tomlinson-Blake and John Shannon. The appellants contended that hours spent at the workplace during ‘sleep-in’ shifts should be paid at the National Minimum Wage, including the hours during which they were permitted to sleep. As a result of the decision, only time where the worker is awake for the purposes of working during these hours will be considered as remunerable work.

In the court's written ruling, Lady Arden said that "sleep-in workers... are not doing time work for the purposes of the national minimum wage if they are not awake".

The judgment also provides a decisive definition of ‘work’ in the context of overnight workers.

The full decision: Royal Mencap Society v Tomlinson-Blake [2021] UKSC 8

“Don’t go off the rails…” – A case law update (Bechtel Limited v High Speed Two (HS2) Limited)
Lawyers in Local Government | 10 March 2021
A short summary of some of the key "takeaways" for local authorities from the most recent high profile procurement litigation, this time featuring the HS2 project. To help ensure your procurements don't go off the rails...

The original winning bidder in the procurement case was also awarded costs in Bechtel Ltd v High Speed Two (HS2) Ltd ((No.2) Costs of the Interested Party) [2021] EWHC 640 (TCC) (23 March 2021)

Publications & Guidance

Judicial Review Reform - The Government Response to the Independent Review of Administrative Law
Ministry of Justice | 18 March 2021
The government has published its response to the Independent Review of Administrative Law. The Government thinks there is merit in exploring the following areas to see whether practical measures could address some of the issues identified in the Report:

  • legislating to clarify the effect of statutory ouster clauses
  • legislating to introduce remedies which are of prospective effect only, to be used by the courts on a discretionary basis
  • legislating that, for challenges of Statutory Instruments, there is a presumption, or a mandatory requirement for any remedy to be prospective only
  • legislating for suspended quashing orders to be presumed or required
  • legislating on the principles which lead to a decision being a nullity by operation of law
  • making further procedural reforms (which would need to be considered by the CPRC)

Read the full report and full Government response.

The House of Commons Library have also produced a briefing, covering the background to the IRAL and why the government is consulting again.


Campaigners seek oral hearing after refusal of permission for statutory review challenge over adoption of Local Plan
Local Government Lawyer | 6 April 2021
A campaign group has filed a request for an oral hearing after a High Court judge refused permission on the papers for a legal challenge over South Oxfordshire District Council’s decision to proceed with its Local Plan 2035.

The claimant, Bioabundance Community Interest Company, said South Oxfordshire had adopted the plan on 10 December 2020 under pressure from Robert Jenrick, Secretary of State for Housing, Communities and Local Government (MHCLG).

COVID passports have ‘significant implications’ for councils
Local Gov | 6 April 2021
Cllr James Jamieson, chairman of the Local Government Association (LGA), said that COVID passports would have ‘significant implications’ for councils.

‘We urge Government to work closely with local government on any proposals for COVID-19 status certification,’ he said. ‘They are likely to bring significant implications for councils, particularly with regards to licensing, enforcement and support to venues and businesses who would have to use them.

The full statement: LGA responds to Prime Minister’s announcement of the next step of the roadmap | Local Government Association

Former elected mayor for Liverpool eyes legal challenge against council over legal costs following arrest
Local Government Lawyer | 31 March 2021
Liverpool City Council’s former elected mayor is expected to take the authority to judicial review over its refusal to pay his legal costs following his arrest in December on suspicion of conspiracy to commit bribery and witness intimidation.

Joe Anderson, who had been the Labour elected mayor since 2012, has denied any involvement in wrongdoing follow his arrest in Merseyside Police’s Operation Aloft investigation. He has said the council should pay his legal expenses as its rules allow for him to be indemnified as he was elected mayor at the time.

NHS trusts give up £2bn business rates dispute with councils
Local Government Lawyer | 30 March 2021
Eleven NHS trusts have abandoned plans to petition the Court of Appeal as part of a dispute with councils over the business rates they have to pay on hospitals. The trusts conceded after a five-year effort that sought to argue that they should be treated as charities and therefore be eligible for reductions on the non-domestic rates payable on the properties they occupy.

If successful, the hospitals would have received a mandatory 80% discount off their business rates tax bill, and councils would have been forced to pay more than £2 billion in backdated business rates rebate.

Ministers face legal challenge over council remote meetings decision | Public Finance
Public Finance | 26 March 2021
Hertfordshire County Council, working with Lawyers in Local Government and the Association of Democratic Services have applied to the High Court arguing that pre-existing legislation already provides for remote meetings.

David Williams, chairman of the County Councils Network, said: “The decision is illogical when you bear in mind the government’s own guidance stipulates that indoor events cannot be organised until 17 May at the earliest.”

MPs launch inquiry into controversial permitted development rights
LocalGov | 24 March 2021
The Housing, Communities and Local Government Committee has launched a new inquiry to examine the Government’s approach to permitted development rights (PDRs).

In recent years, the Government has expanded the use of PDRs. In 2020, they legislated to permit conversion between a much wider range of commercial and retail premises, and created new PDRs to allow unused office buildings to be converted into residential property. The new legislation also gave homeowners the right to add additional stories to existing post-war homes.

The inquiry: Permitted development rights - Committees - UK Parliament

Local government bodies celebrate revocation of exit payment cap regulations
Lawyers in Local Government | 22 March 2021
LLG and ALACE have welcomed the revocation of the Restriction of Public Sector Exit Payments Regulations 2020 on 19 March. This is a direct outcome of their judicial review claim seeking to have the regulations quashed.

LLG and ALACE were deeply concerned that the 2020 Regulations were rushed and ill thought through, made without proper consideration of the detrimental impact on local government staff. Indeed, at the time of implementation the associated changes to the local government pension scheme were still the subject of consultation. Of great concern was the retrospective effect of the regulations, removing the hard earned right to receive an unreduced pension if made redundant over the age of 55.

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Resource Library

All Bevan Brittan articles and news
Bevan Brittan COVID-19 Insight Information Hub


A landscape of change: the future of the built environment
The interplay between inquests and incident investigations

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All forthcoming webinars

‘Place’ and integrated care: what is the future of the relationship between local government and the NHS
Wednesday 12 May: 12.00 - 13.00

Immigration: Right to Work Checks - a refresher
Wednesday 9 June: 11.00 - 11.45

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