The NFSE, a group of taxpayers, claimed the Inland Revenue Commissioners rules for levying tax on casual wages for Fleet Street newspaper staff, was unlawful.

The Court of Appeal held the NFSE had sufficient interest in the matter for the application to be heard, and assumed the scheme was unlawful.

The question of sufficient interest had to be resolved in relation to what was known by the court of the matter under review, and on the evidence the tax scheme was a lawful exercise of the IRC's discretion.

Lord Diplock dissented, holding the NFSE had sufficient interest but the case failed on its merits.

Lord Scarman disagreed with the majority, adopting a broader approach to standing but holding that the NFSE did not have a sufficient interest because they did not have an arguable case.