R & RK v Hertfordshire County Council (SEN): [2025] UKUT 381 (AAC)

Upper Tribunal Administrative Appeals Chamber decision by Judge Jacobs on 6 November 2025.

Read the full decision in UA-2025-000169-HS.

Judicial Summary

Children and Families Act 2024 – section 21 - relationship between special educational provision and health care provision – order for consideration – whether tribunal right to treat occupational therapy as health care provision – scope of appeal to First-tier Tribunal’s under section 51 – materiality of any mistake the tribunal may have made in applying section 21.

Updates to this page

Published 7 January 2026