R (Alconbury Developments Ltd) v Secretary of State for the Environment, Transport and the Regions [2001] UKHL 23 is a UK constitutional law case, concerning judicial review.
The claimants argued that (1) the decisions affected their civil rights, (2) under the ECHR art 6(1) those questions should be decided by an independent and impartial tribunal, with court review, not a Minister, (3) there was insufficient judicial control for ECHR art 6(1) because the statutory appeals did not allow for a rehearing on the merits.
The House of Lords held that, although civil rights were affected and there should be independent oversight, ECHR art 6(1) did not require a court to rehear the merits of a decision.
Lord Slynn said proportionality should be recognised as a general principle of English law: "It is self-evident that ministerial or departmental policy cannot be regarded as disqualifying bias.
One of the commonest administrative mechanisms is to give a minister power to make or confirm an order after hearing objections to it.