Sherlock v Lloyd

The case of Sherlock v Lloyd involved a dispute between the plaintiff, Sherlock, and the defendant, Lloyd, a member of a medical panel. The dispute arose from the medical panel's opinion on medical questions referred to them by the County Court, which the plaintiff found inadequate in terms of the reasons provided. The plaintiff sought judicial review of the panel's decision, arguing that the inadequacies in the reasons provided constituted an error of law. The central legal issues before the court were whether the inadequacy of the reasons constituted an error of law, whether the function of the panel was judicial or administrative, and whether the relevant statute had enlarged the principles of natural justice.

The court considered whether the panel's function was judicial or administrative, noting that the medical panel was established under statute and its role involved providing expert medical opinions. The court determined that the panel's function was primarily administrative, as it involved the application of expertise rather than the exercise of judicial power. The court also examined whether the statute had enlarged the principles of natural justice, finding that the statute did not explicitly require the panel to provide detailed reasons for its decisions. The court concluded that, given the administrative nature of the panel's function and the absence of statutory requirements for detailed reasons, the inadequacy of the reasons did not constitute an error of law warranting judicial review.

Based on its findings, the court dismissed the plaintiff's application for judicial review. The court held that the medical panel's function was administrative, and the statute did not impose a requirement for detailed reasons. Therefore, the inadequacy of the reasons provided by the panel did not amount to an error of law. The court did not order any specific relief, as the plaintiff's application was dismissed on the grounds that no error of law was found.