When an LA can refuse to name a school or college because it is incompatible with the efficient use of resources

Crane v Lancashire County Council [1997] ELR 377: An LA must first establish whether the parents’ choice of placement is more expensive than that offered by the authority.  If it is, the LA must make the decision as to whether the additional expenditure involved in meeting the parent’s preference is justified.

Essex CC v the SEND Tribunal [2006] EWHC 1105 (Admin): A parent or young person’s preference can only be displaced on the grounds of being ‘incompatible with the efficient use of resources’ where the extra cost is significant or disproportionate. A difference of between £2000-£4000 was not found to be ‘incompatible’.