The plaintiff unsuccessfully challenged the Minister's initial refusal to issue a certificate of compliance in respect of a property for which tax reliefs under the student accommodation scheme were to be sought. The case emphasises the importance of the certification requirements in the context of property tax reliefs. The Court's observation that the right to appeal to the Appeal Commissioners contained in section 372AT Taxes Consolidation Act 1997 was a factor for the court to consider in exercising its discretion to give relief by way of judicial review proceedings is perhaps of general interest.