However, for all his efforts, his single greatest achievement was the imposition of a duty on peanuts.

Amongst those consequences, he said, was the imposition of a duty to act fairly towards those who are directly affected by an intervention decision.

In some instances constraints would be imposed indirectly through the imposition of a duty to provide reasons; in other cases the courts hinted at the limits they would set, such as if the decision was perverse or made in bad faith.