MB v Hertfordshire County Council (SEN): [2026] UKUT 86 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge Citron on 18 February 2026.
Read the full decision in .
Judicial Summary
The First-tier Tribunal rejected a number of proposed ‘provisions’ for inclusion in Section F of the Appellant’s EHC plan. The Appellant was an 18-year-old with special educational needs who attended a college, and the proposed provisions included a drama group, volunteering activities, gym sessions and membership, a therapeutic gardening course, and a programme to help her with travelling. The Upper Tribunal sets out the basic conditions to be satisfied if such proposals were to be included in Section F (see paragraph 9 of the decision) and concludes that the First-tier Tribunal erred in not adequately explaining why they were not satisfied in this case. Despite this conclusion, the Upper Tribunal refrained from setting the tribunal decision aside, as the EHC plan in question had now been replaced by a new EHC plan for the Appellant.