R v IRC, ex parte Unilever [1996]

Applicant
argued IRC should have allowed company to claim tax relief for certain period.
Outside
time limit, but this time limit had not been strictly insisted upon by Revenue
in past.
Court
of Appeal found for applicant.
Though
Revenue had not made unqualified and unambiguous representation in sense
mentioned in MFK, would nonetheless
be so unfair as to amount to abuse of power to allow Revenue to insist on
strict time limit.
MFK category of legitimate expectation was but one head of Wednesbury unreasonableness.