LL and MM v Telford and Wrekin Council (SEN): Specialist Hub Naming in EHC Plan Upheld
Summary
The Upper Tribunal Administrative Appeals Chamber dismissed an appeal challenging whether a specialist hub operated by a maintained special school could be lawfully named in Section I of a child's Education, Health and Care (EHC) plan. Judge Stout upheld the First-tier Tribunal's decision, ruling that naming the hub is permissible when the special school of which it forms part is already named in Section I, consistent with prior decisions in TB v Essex County Council and MA v Royal Borough of Kensington and Chelsea.
What changed
The Upper Tribunal upheld the First-tier Tribunal's decision permitting a specialist hub operated by a maintained special school to be named in Section I of an EHC plan. The Tribunal held that a specialist hub is properly treated as part of the maintained special school that operates it, not as a separate institution. Under regulation 12(1)(i) of the Special Educational Needs and Disability Regulations 2014, provided the special school is named in Section I, it is lawful also to refer to the hub, including by description or name in Section F where necessary to properly identify required provision. The decision clarifies the permissible scope for naming specialist educational provision in EHC plans.
Local authorities responsible for drafting EHC plans should ensure consistency with this ruling. The decision confirms that naming specialist hubs is not prohibited by the 2014 Regulations when the parent special school is named, and that such wording may be included where parties agree under regulation 43(1) or as a consequential amendment under regulation 43(2)(f). This provides clarity on an area of law previously subject to conflicting interpretations across different Upper Tribunal decisions.
What to do next
- Review EHC plan drafting practices for consistency with Upper Tribunal ruling on specialist hub naming
- Ensure special schools are named in Section I before referencing associated specialist hubs
Archived snapshot
Apr 15, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
LL and MM v Telford and Wrekin Council (SEN): [2026] UKUT 129 (AAC)
Upper Tribunal Administrative Appeals Chamber decision by Judge Stout on 18 March 2026.
From: HM Courts & Tribunals Service and Upper Tribunal (Administrative Appeals Chamber) Published 15 April 2026 Categories: Special educational needs Judges: Stout, H Decision date: 18 March 2026 Read the full decision in UA-2025-001191-HS.
Judicial Summary
The First‑tier Tribunal named in Section I of the appellant’s child’s EHC plan a specialist hub operated by a maintained special school but located on the site of a mainstream primary school. The parents contended that it was unlawful to name the hub in Section I.
The Upper Tribunal dismissed the appeal, holding:
- The Tribunal was right to treat this specialist hub as part of the maintained special school that operated it, and not as a separate school or institution, consistently with the approach in TB v Essex County Council [2013] UKUT 0534 (AAC), [2014] ELR 47 and MA v Royal Borough of Kensington and Chelsea [2015] UKUT 0186 (AAC);
- Provided the special school of which the hub is a part is named in Section I, it is lawful also to refer to the hub. This is not prohibited by regulation 12(1)(i) of The Special Educational Needs and Disability Regulations 2014 (SI 2014/1530) and the Tribunal has power to include such wording in appropriate cases where the parties agree (by virtue of regulation 43(1)) or by order as a “consequential amendment” under regulation 43(2)(f). (East Sussex County Council v TW [2016] UKUT 0528 (AAC) and NN v Cheshire East Council [2021] UKUT 220 (AAC) distinguished);
- The hub may also be referred to by description or by name in Section F where that is necessary to ensure that the provision reasonably required to meet the child’s special educational needs is properly identified;
- Even if the Upper Tribunal was wrong and inclusion of reference to the hub in Section I was an error of law, it was not a material one in this case. The decision of the First‑tier Tribunal was therefore upheld.
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Published 15 April 2026
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