BZP and BZQ v Warwickshire County Council (SEN): [2026] UKUT 113 (AAC)

Upper Tribunal Administrative Appeals Chamber decision by Judge Jacobs on 09 March 2026.

• From: HM Courts & Tribunals Service and Upper Tribunal (Administrative Appeals Chamber)
• Published: 31 March 2026

• Categories: Special educational needs and Tribunal procedure and practice
• Sub-categories: Special educational needs - special educational provision - other and Tribunal procedure and practice - tribunal jurisdiction
• Judges: Jacobs, E
• Decision date: 9 March 2026

Read the full decision in UA-2025-000578-HS.

Judicial Summary

Summary: Tribunal practice and procedure (including Upper Tribunal) – tribunal jurisdiction (34.10) First-tier Tribunal reviewed its decision in part – remaining part of decision subject to appeal to Upper Tribunal.

Summary: Special educational needs – special educational provision – other (85.4) Ratio of adults to pupils in class – lack of evidence to support proposed inclusion in plan – ‘small class’ sufficiently precise in context. Provision for psychotherapy – lack of appropriate evidence to justify inclusion – Upper Tribunal could not take fresh evidence into account.

Published 31 March 2026