How we help Get support SEN and disability law SEN and disability case law Case summaries EHC plans need to be specific and clear R v The Secretary of State for Education and Science, ex parte E [1992] 1 FLR 377 CA: Statements (now EHC plans) must not be vaguely worded. Additionally, the LA must include special educational provision (in what is now Section F) for each and every special educational need identified. EC v North East Lincolnshire LA (HS) [2015] UKUT 0648 (AAC) [2016] ELR 109: The First-tier Tribunal should not ‘rubber stamp’ an inadequately vague Statement or EHC plan.