R (Sainsbury’s Supermarkets Ltd) v Wolverhampton CC [2010] UKSC 20 is an English public law case involving invalid considerations of (factors considered by) a local council in making a compulsory purchase order.

Judicial review was available and upheld in this case on one or more of four available grounds, namely: error of law, irrationality, serious procedural irregularity, and action for an improper purpose.

The Council took into account Tesco's commitment to contribute financially to public assets at an off-site ("Royal Hospital") site with no proven real connection in issuing its approval.

As Lord Collins says in his conclusions at para 71 of his judgment, a real (rather than a fanciful or remote) connection must be shown between any off-site benefits and the proposed redevelopment for which a compulsory purchase order is proposed.Lady Hale said the following.

Under the new version of section 226(1), the permissibility of some development (together with a reasonable prospect of its actually taking place) should be a sine qua non [i.e. an absolute] for compulsory acquisition in order to "facilitate" it.