“…The authority cited by Coulson LJ for that proposition was the decision of Simler J in Chakrabarty v Ipswich Hospital NHS Trust[2014] EWHC 2735 (QB); [2014] Med LR 379. In that case Simler J said, at para. 114:…”
“…ies suggest that there is no freestanding obligation to act fairly which is separate from the term of trust and confidence: see Chakrabarty v Ipswich NHS Trust [2014] EWHC 2735 (QB). And in Braganza v BP Shipping Limited & Another [2015] 1 WLR 1661, Baroness Hale referred to the approach in judicial review cases, and explained ([24]) that …”