Padfield v Minister of Agriculture, Fisheries and Food
[1968] AC 997
判决理由
A statutory discretion must be exercised to promote the policy and objects of the Act. A minister cannot refuse to exercise a discretion for improper reasons or to frustrate the purpose of the legislation.
事实
The Agricultural Marketing Act 1958 allowed the minister to refer complaints about milk marketing schemes to a committee of investigation. South-east dairy farmers complained about the pricing scheme. The minister refused to refer the complaint, fearing the committee's recommendations would be politically embarrassing.
判决摘要
The House of Lords held the minister's refusal unlawful. His reasons for refusing to refer the complaint were improper — he was not entitled to use his discretion to frustrate the purpose of the statute. The discretion had to be exercised to promote the Act's policy objectives.
关键引述
"Parliament must have conferred the discretion with the intention that it should be used to promote the policy and objects of the Act."
— Lord Reid
后续处理
Leading authority on the principle that statutory discretion must be exercised for proper purposes. Frequently cited in judicial review cases.