- The decision, taken on the basis of the travel and access criteria alone, failed to take into account relevant considerations, namely the other criteria and/or the outcome of the public
consultation, and was unlawful and/or Wednesbury unreasonable.
- The methodology used for the Transport criteria was flawed in that it failed to take into account relevant considerations, namely Wythenshawe Hospital’s connections with the A6 relief road,
helipad and proximity to Manchester Airport, which rendered the decision unlawful and/or Wednesbury unreasonable.
- The decision was taken on a fundamentally different basis from that which was contained within the public consultation document, namely that the travel standards were applied to a wider catchment
area outside of Greater Manchester, rendering the decision procedurally unfair and/or unreasonable. Further and/or in the alternative, the Equalities Impact Assessment failed to give due regard to
those people living in the widener catchment area and/or the public sector equality duty.
- The failure to consult upon or take into account co-dependencies requiring co-location at Wythenshawe Hospital was unlawful and/or in the alternative, to the extent that co-dependencies were
taken into account, the conclusions were irrational and/or unreasonable