consulted. Effectively, this proposition grants courts the discretion to ascertain whether the public interest is better served by ordering an authority to perform its undertaking than to frustrate it. Ex parte Khan is also regarded as the first case in which an individual relied on a general policy, as opposed to a specific representation or a policy drawn for a closed class of persons, as the grounds for the expectation of a benefit. While the case mooted the idea of a substantive legitimate expectation, the doctrine was more completely developed in the High Court judgment of R v Ministry of Agriculture, Fisheries and Food, ex parte Hamble (Off-shore) Fisheries Ltd. (1995). Justice Stephen Sedley attempted to widen the Court's protection of legitimate expectations by including "substantive protection of a substantive legitimate expectation". He rejected the proposition that legitimate expectations are limited to procedural grounds by stating: "It is difficult to see why it is any less unfair to frustrate a legitimate expectation that something will or will not be done by the decision-maker than it is to frustrate a legitimate expectation that the applicant will be listened to before the decision-maker decides whether to take a particular step." When a court protects an applicant's substantive legitimate expectation, it is effectively mandating the outcome of a public body's decision-making process. One criticism is that this undesirably fetters the body's discretion as it will no longer be able to formulate policy without constraints. Nevertheless, it has been acknowledged that protecting substantive legitimate expectations ensures good administration. Consistency and fairness are reinforced in decision-making processes where the administrative power to alter policy is not used to unduly frustrate legitimate expectations. Furthermore, when a public body acts contrary to what it had induced an individual to expect, it may cause that individual severe hardship, especially if he or she relied on the representation and there is no satisfactory alternative to the substance of the promise. The problem is alleviated if the court orders that the individual's legitimate expectation be given effect. Categorical approach Substantive legitimate expectation was definitively recognized as a ground of judicial review in the UK in ex parte Coughlan. The case involved a health authority which resiled from its explicit promise to the disabled applicant that a facility at which she was living would be her "home for life". The Court of Appeal affirmed that the applicant had a legitimate expectation