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(c) The Secretary of State has fettered his discretion, has failed to discharge an appropriate duty of inquiry and/or has failed to properly exercise his constitutional function of advising Her Majesty and has done so, in particular, by:
(d) The failure to provide a clearly set out and effective complaints system is a further instance of procedural unfairness and in breach of the applicant's procedural legitimate expectation engendered by the guidance for applicants.
(e) The Panel's decision not to advise that the applicant be recommended for appointment was irrational in the Wednesbury sense and was irrational, in particular, was irrational in failing to determine that the applicant attained the 'standard of excellence' having regard to the applicant's self-assessment form and references as a whole.
(f) The Panel's decision on reconsideration, following referral back by the Complaints Committee, was vitiated by both actual and apparent bias.
(g) Having regard to the findings of the Complaints Committee, it was irrational for the Secretary of State to continue to act upon the Panel's recommendations.
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