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In R. Vs. Panel on Take-overs and Mergers, ex parte Datafin plc and
another [1987 (1) All ER 564] the Court exercised the power of the judicial
review over a private body.
The grounds on which judicial review was given are:
(a) The Panel, although self-regulating, do not operate
consensually or voluntary but had imposed a collective code on
those within its ambit;
(b) The Panel had been performing a public duty as manifested by
the government's willingness to limit legislation in the area and
to use the Panel as a part of its regulatory machinery. There
had been an "implied devolution of power" by the Government
to the Panel in view of the fact that certain legislation
presupposed its existence.