Judicial review: the Cameron case

The decision in Ian Cameron & Ors v HMRC represents a rare judicial review success for the taxpayer, in which the High Court held that the taxpayer had a legitimate expectation that it would be taxed in accordance with a concession given and published by HMRC. The case is noteworthy in considering the question of, once a legitimate expectation has been acquired, what steps does HMRC need to take for it to cease? Publication of the change to known agents is not enough, as publication must be made to the whole of the class. The degree of formality of publication is also relevant.