LL and MM v Telford and Wrekin Council (SEN): [2026] UKUT 129 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge Stout on 18 March 2026.
Read the full decision in .
Judicial Summary
The First‑tier Tribunal named in Section I of the appellant’s child’s EHC plan a specialist hub operated by a maintained special school but located on the site of a mainstream primary school. The parents contended that it was unlawful to name the hub in Section I.
The Upper Tribunal dismissed the appeal, holding:
- The Tribunal was right to treat this specialist hub as part of the maintained special school that operated it, and not as a separate school or institution, consistently with the approach in TB v Essex County Council [2013] UKUT 0534 (AAC), [2014] ELR 47 and MA v Royal Borough of Kensington and Chelsea [2015] UKUT 0186 (AAC);
- Provided the special school of which the hub is a part is named in Section I, it is lawful also to refer to the hub. This is not prohibited by regulation 12(1)(i) of The Special Educational Needs and Disability Regulations 2014 (SI 2014/1530) and the Tribunal has power to include such wording in appropriate cases where the parties agree (by virtue of regulation 43(1)) or by order as a “consequential amendment” under regulation 43(2)(f). (East Sussex County Council v TW [2016] UKUT 0528 (AAC) and NN v Cheshire East Council [2021] UKUT 220 (AAC) distinguished);
- The hub may also be referred to by description or by name in Section F where that is necessary to ensure that the provision reasonably required to meet the child’s special educational needs is properly identified;
- Even if the Upper Tribunal was wrong and inclusion of reference to the hub in Section I was an error of law, it was not a material one in this case.
The decision of the First‑tier Tribunal was therefore upheld.
Updates to this page
Published 15 April 2026