It extended the scope of judicial review in English law to private bodies exercising public functions.

The Court of Appeal held that the powers exercised by the Panel (regulating take-overs and enforcing a code of conduct on them) were essentially in the domain of public law and formed part of the Government's scheme to regulate the City.

In recent years, the Government has delegated many of its powers to formally private bodies, which nevertheless can make decisions affecting individual citizens and the society at large.

In the later case of R v Panel on Takeovers and Mergers, ex parte Guinness plc,[1] the judicial authority of the Panel was tested further in respect of the manner in which it handles investigations into breaches of the City Code on Takeovers and Mergers.

In this case, the Panel refused to adjourn the appellant's hearing which related to its takeover of Distillers Co plc, in undisclosed concert with a Swiss bank, for which the Court of Appeal held that unless there was any real injustice caused by the Panel's procedure, it would take exceptional circumstances for the court to intervene (particularly if the appellant had not made use of the Panel's own appeals tribunal, as was the case).