Inadequate Reasons for Planning Refusals

When a planning application is refused, the authority must explain why.

That obligation is not a formality. A refusal decision must contain reasons that are sufficiently clear, precise, and intelligible to explain how and why the authority reached its conclusion.

Where reasons are vague, generic, or disconnected from any recorded assessment, the decision may be procedurally defective due to inadequate reasons.

This page explains what constitutes inadequate reasons in planning refusals, why it matters, and how the issue is assessed in practice.

Why reasons matter in planning decisions

The requirement to give reasons serves several fundamental purposes:

to explain to the applicant why the proposal was refused;
to demonstrate that material considerations were properly assessed;
to enable effective challenge or appeal; and
to show that the decision was reached rationally and lawfully.

A refusal that does not explain its reasoning frustrates all of these purposes.

What makes reasons inadequate?

Reasons are inadequate where they fail to convey, in a clear and intelligible way, the reasoning process that led to refusal.

Common indicators include:

generic policy references without explanation;
assertions of harm without describing how that harm arises;
conclusions that are not linked to any evidence or assessment;
reasons that merely restate objections or consultation responses;
language that is conclusory rather than analytical.

The issue is not brevity. Short reasons can be lawful. The issue is whether the reasoning can be understood.

Reasons vs evidence

A common misconception is that the existence of evidence elsewhere in the file cures inadequate reasons.

It does not.

Reasons must:

identify the issue relied upon;
explain the authority’s conclusion on that issue; and
show how that conclusion informed the refusal.

If the reasoning is not apparent from the decision notice or decision record, the authority cannot rely on later reconstruction to explain what it meant.

Committee reports and inadequate reasons

In many cases, the refusal reasons are short because the authority relies on the officer report or committee discussion to supply the reasoning.

That approach only works if the reasoning is actually present and clearly recorded.

Problems arise where:

the report identifies issues but does not reach conclusions;
committee debate raises concerns without resolving them;
the final decision departs from the officer recommendation without explanation; or
there is no clear link between discussion and refusal reasons.

In those circumstances, the reasons for refusal may be inadequate even if the issues were discussed.

Inadequate reasons and public-law risk

Inadequate reasons create public-law risk because they:

prevent the applicant from understanding the decision;
obscure whether material considerations were properly assessed;
undermine confidence that the decision was rational; and
frustrate effective challenge or appeal.

The issue is procedural, not merits-based.

A decision can be substantively defensible in theory but procedurally unsafe if its reasoning is not properly recorded.

How inadequate reasons are identified in practice

Under time pressure, advisers often assess adequacy of reasons by asking:

Can the reasoning behind each refusal reason be clearly understood?
Is that reasoning linked to any recorded assessment?
Does the decision explain how conclusions were reached?
Or does it merely assert outcomes?

If the reasoning cannot be reconstructed without inference or assumption, the reasons may be inadequate.

Relationship to evidential sufficiency and unlawful deferral

Inadequate reasons often coexist with other governance failures.

Evidential sufficiency failures arise where conclusions lack supporting assessment.
Unlawful deferral arises where assessment is postponed.
Inadequate reasons arise where conclusions are asserted without explanation.

Together, these failures can indicate that the decision-making process was not lawfully completed at the point of refusal.

What this analysis does not determine

This analysis does not:

decide appeal outcomes;
determine whether relief would be granted;
assess planning balance; or
replace legal judgement.

It assesses whether the authority has met its obligation to explain its decision.

The core test

Do the refusal reasons clearly and intelligibly explain how the authority reached its conclusions?

If they do not, the decision may be procedurally unsafe regardless of the underlying planning issues.

PGAT

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