LJ distilled general principles applying to employment cases:
Employees of public bodies should pursue their cases in the normal way outside
However JR could be used if public employee affected by a disciplinary body
established under statute or prerogative.
it had a sufficient public law element, Ord 53 could be used.
was attacking a decision of general application and doing so on Wednesbury grounds (eg GCHQ)
Even where review not available because disciplinary procedures are purely
domestic, might still be possible for employee to seek declaration outside Ord
53 to ensure proceedings conducted fairly.
latent tension between this case and Roy.
case sees ordinary employment disputes as being litigated by writ outside Ord
53, with matters of more general importance raising Wednesbury issues brought by way of JR.
if some public law issues involved too.]