legality of decisions on the grounds that the decision-maker "had acted outwith the powers conferred upon it". Although initially unclear, the nature and boundaries of the doctrine of legitimate expectation have been elucidated by seminal cases such as Council of Civil Service Unions v Minister for the Civil Service (the GCHQ case, 1983). and R v North and East Devon Health Authority, ex parte Coughlan (1999). Notwithstanding efforts of the courts, some ambiguity as to when legitimate expectations arise persisted. In response, Lord Justice of Appeal John Laws proposed the aspiration of "good administration" as a justification for the protection of legitimate expectations. Legal framework A procedural legitimate expectation is created when a representation is made by a public authority that it will follow a certain procedure before making a decision on the substantive merits of a particular case. Examples of procedural legitimate expectations include an expectation to be consulted and to a fair hearing. A substantive legitimate expectation is formed where a representation is made by an authority as to the final decision and outcome that the authority will make in a particular case. Upon reviewing a claim for the protection of a legitimate expectation against a public authority's decision, courts will deliberate over three key considerations: The situations and circumstances in which legitimate expectations arise. Instances in which it would be unlawful for the public authority to frustrate such an expectation. The remedies that would be available to the aggrieved party if it is found that the public authority had unlawfully frustrated a legitimate expectation. When does an expectation become legitimate? When determining if a legitimate expectation is present, the required conditions are as follows: The representation must be clear, unambiguous, and not have any relevant qualification. The expectation must be induced by the behaviour of the public authority. The representation must have been made by someone who had actual or apparent authority. The representation must be applicable to the aggrieved parties. Courts take into account not only the reasonableness of the expectation but other considerations such as the nature of representation made. In the GCHQ case, Lord Diplock stated that a legitimate expectation is one which "has consequences to which effect will be given in public law, whereas an expectation or hope that some benefit or advantage would continue to be enjoyed, although it might well be entertained by a 'reasonable' man, would not necessarily have such