“…W.L.R. 1593, the decision of the Supreme Court in R. (on the application of Cart) v Upper Tribunal [2011] UKSC 28, [2012] 1 A.C. 663 and the decision of the Privy Council in Kemper Reinsurance Co. v Minister of Finance [2000] 1 A.C. 1 (paragraph 16). He referred…”
“…ion between jurisdictional and non-jurisdictional error achieved by Anisminic v Foreign Compensation Commission [1996] 2 A.C. 147 and R (Cart) v Upper Tribunal [2012] 1 A.C. 663. But neither Anisminic nor Cart had anything to say about issue estoppel or the requirement of issue estoppel that the earlier decision be that of a court of c…”