to protect an ultra vires determination, judicial review was not precluded. Though Anisminic did not expressly abolish the distinction between jurisdictional and non-jurisdictional errors of law, in R v Lord President of the Privy Council, ex parte Page (1992) the House of Lords noted that:

Thus, in English law all errors of law are now to be considered as jurisdictional and ultra vires in a broad sense of the term. This implies that ouster clauses should not be effective against any error of law.