Greenwich transport training decision for disabled young person survives challenge

The High Court has refused permission for a disabled young person to bring judicial review proceedings against a London borough's decision to offer independent travel training rather than direct taxi transport to college, finding the authority's approach neither irrational nor procedurally flawed.

In R (HUR) v Royal Borough of Greenwich [2026] EWHC 1978 (Admin), Duncan Atkinson KC, sitting as a Deputy High Court Judge, held that the council had conducted the sensitive and careful assessment required when weighing competing evidence about how best to support a 23-year-old with complex needs travelling to college.

The claimant, who has autism, ADHD, epilepsy, hemiparesis and an anxiety disorder, began a college placement in Bexley in September 2025. Greenwich, which had previously funded taxi transport at earlier stages of his education, declined to continue that arrangement and instead offered independent travel training, under which a qualified trainer would accompany him on journeys until he could travel safely on his own.

The claimant's mother appealed unsuccessfully through the council's two-stage process, submitting evidence including a letter from a consultant psychiatrist, Dr John Carroll, who described it as unrealistic to expect the claimant to spend over an hour on crowded buses given his mental health and sensory needs. The mother also highlighted the strain of accompanying him herself, given her responsibilities as an unpaid carer for her partner.

The council's Stage 2 panel considered that material alongside the claimant's Education, Health and Care Plan and an annual college review, both of which indicated he was developing independence skills, had identified travel training as a goal, and was engaging well with structured support. The panel concluded that independent travel training represented the most proportionate response, consistent with statutory guidance encouraging progression toward adulthood.

The claimant argued that the decision amounted to process irrationality, contending the council had failed to grapple meaningfully with Dr Carroll's evidence and had made an unexplained leap in reasoning. The judge rejected this characterisation, noting that Dr Carroll's letter did not explain the nature or duration of his relationship with the claimant, nor did it address whether escorted travel might address his concerns, unlike the college review and the care plan, both of which spoke directly to that question.

Applying the test for process rationality set out in R (KP) v Secretary of State for Foreign and Commonwealth Affairs [2025] EWHC 370 (Admin), the judge found no unexplained evidential gap in the council's reasoning. The decision, properly understood, was not a refusal of transport support but the exercise of the council's discretion under section 508F of the Education Act 1996 to select an alternative form of assistance, one which retained an escort for the claimant throughout the journey until he could travel independently.

The judge also noted an apparent misunderstanding on the part of the claimant's mother as to what the training actually involved, while accepting her account was given honestly. Correspondence and a meeting transcript demonstrated that the accompanied nature of the training had been explained to her in advance.

Permission was refused on the sole ground advanced, with the judge observing that the arrangement remained subject to ongoing review, offering the claimant a route to challenge it further should it prove unworkable in practice.