East Riding of Yorkshire Council v Bowers: [2026] UKUT 31 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge Citron on 26 January 2026.
Read the full decision in .
Judicial Summary
This was an appeal by the local authority against the First-tier Tribunal’s ordering inclusion of a certain number of hours per week of golf coaching and gym training, in Section F of a young person’s Education Health and Care plan (which sets out the special educational provision required). The Upper Tribunal held that inclusion of the golf and gym provision was an error of law, because it did not have the necessary nexus with the young person’s special educational needs, as set out in Section B of her EHC plan. The necessary nexus is that the special educational needs set out in Section B must call for, and require, the special educational provision in Section F. The decision of the First-tier Tribunal was set aside as respects Section F, and also as respects Section I, as Section I could not be determined without knowing the special educational provision required, set out in Section F. Those matters were remitted to a fresh tribunal for reconsideration.