LL and MM v Telford and Wrekin Council - Naming Specialist Hub in EHC Plan
Summary
The Upper Tribunal (Administrative Appeals Chamber) dismissed an appeal concerning 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. The Tribunal held that such a hub is part of the maintained special school and may be named in Section I alongside the parent school, provided the special school is also named. The decision upholds the approach in prior cases including TB v Essex County Council [2013] and MA v Royal Borough of Kensington and Chelsea [2015].
What changed
The Upper Tribunal held that a specialist hub operated by a maintained special school may be named in Section I of an EHC plan without breaching regulation 12(1)(i) of the Special Educational Needs and Disability Regulations 2014, provided the parent special school is also named. The Tribunal confirmed this is lawful under regulation 43(1) where parties agree, or under regulation 43(2)(f) as a consequential amendment ordered by the Tribunal.
Local authorities, special schools, and parents of children with EHC plans should note that specialist hubs may now be referenced by name or description in Section F where necessary to properly identify required special educational provisions. This decision provides clarity on EHC plan drafting for future cases and aligns with the approach established in TB v Essex County Council and subsequent decisions.
What to do next
- Monitor Upper Tribunal decisions for updates on EHC plan naming requirements
- Review current EHC plan drafting practices to ensure specialist hubs are named consistently with this decision
- Consult legal counsel when preparing EHC plans that reference specialist hub provisions
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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