circumstances a procedural right alone was insufficient for producing a fair outcome as "procedure and substance are intertwined, with procedural rights reinforcing substantive ones, and vice-versa ". The Schmidt case illustrates that the courts' protection of a procedural right inevitably leads to a substantive outcome. The plaintiffs here challenged a decision to refuse renewal of their residence permits on the grounds that they had not been given a hearing before the decision was reached. This argument was rejected as the original permits had been issued for only a certain time, which had since expired. However, Lord Denning, the Master of the Rolls, said that had the plaintiffs' residence permits been revoked before they expired, they "would have a legitimate expectation of being allowed to stay for the permitted time". The Court of Appeal in effect envisaged procedural protection of a substantive expectation of being allowed to stay in the UK. Substantive legitimate expectations A substantive legitimate expectation arises where a public body makes a "lawful representation that an individual will receive, or continue to receive, a substantive benefit of some kind". Development of substantive protection In R v Secretary of State for the Home Department, ex parte Hargreaves (1996), the Court of Appeal of England and Wales initially rejected the argument that the courts could perform a substantive review function beyond that permitted by Wednesbury unreasonableness. In contrast, in the earlier case of R v Secretary of State for the Home Department, ex parte Khan (1984), the applicant had argued that the government had unfairly failed to apply the criteria in a government circular that outlined when a family could adopt children living outside the UK. In the Court of Appeal's judgment, Lord Justice of Appeal Hubert Parker surmised that expanding the doctrine of legitimate expectation to protect a substantive element would not necessarily be inconsistent with the principle underlying the doctrine. He stated that "just as [other cases have established that public authorities cannot] resile from an undertaking and change [their] policy without giving a fair hearing so, in principle, the Secretary of State, if he undertakes to allow in persons if certain conditions are satisfied, should not in my view be entitled to resile from that undertaking without affording interested persons a hearing". This introduced the idea that in certain cases the courts would consider if policy changes were justified even when the affected parties had already been