• In the case of R v Hull University Visitor ex parte page [1993] ac 682, it was found that the principle held in Anisminic is inapplicable to the decisions of university visitors.

Facts of the Case

  • C was a university lecturer who was made redundant under the university’s statutes.
  • C petitioned the Visitor of the University but was dismissed.
  • C then sought for judicial review of the decision made by the Visitor on the basis that the rejection contravened the university statute as was therefore ultra vires.


  • Could the visitor’s decision fall subject to judicial review?
  • Was there a misconstruction by the visitor

Held by the House of Lords

  • The House of Lords held that the Visitor did not act outside of their jurisdiction and any error of law that may have been committed could not be subject to judicial review.

Lord Browne-Wilkinson

  • His Lordship clarified the general rule with regards to an error of law and stated that “…in general any error of law made by an administrative tribunal or inferior court in reaching its decision can be quashed for error of law.” [701C]
  • After clarifying the general position, his lordship concluded that the general rule is inapplicable to visitors, the reasons were twofold:
  • A visitor applies a “peculiar, domestic law of which he is the sole arbiter and of which the courts have no cognisance” and an error under such domestic law is not capable of being an error of the general law that can be reviewed. [702C]
  • The longstanding precedent that the “common law has for 300 years recognised that the visitor’s decision on questions of fact and law are final and conclusive and are not to be reviewed by the courts.” [703B]

Lord Slynn (dissenting)

  • His Lordship dissented the majority decision and found that the general rule should extend to visitors and expressed that he is “not persuaded that the jurisdiction of the visitor involves such exceptional considerations that this principle should be departed from and that some grounds be accepted and others held not to be available for the purposes of judicial review.” [709D]