The judgment extensively referenced pivotal cases that shape the interpretation of Article 14 in the context of social security:

• Wandsworth London Borough Council v Michalak [2003] 1 WLR 617: Established foundational questions for assessing discrimination claims under Article 14.
• Ghaidan v Godin-Mendoza [2004] UKHL 30: Clarified the application of Article 14, emphasizing the importance of considering both substantive rights and protected characteristics.
• R (DA & DS) v Secretary of State for Work and Pensions [2019] 1 WLR 3289: Provided contemporary insights into the broad interpretation of "status" under Article 14.
• A v Secretary of State for the Home Department [2005] 2 AC 68: Highlighted the necessity to justify differences in treatment, focusing on the reasons behind such legislative provisions.
• Re Brewster [2017] 1 WLR 519: Discussed the significance of rational policy aims over the mere longevity of legislation in justifying differential treatment.

These precedents collectively informed the court's assessment, ensuring that the judgment was firmly grounded in established legal principles while addressing the nuances of this specific case.

The court employed a four-tiered analytical framework, often referred to as the "Stott questions," to evaluate the discrimination claim:

• Do the circumstances fall within the ambit of one or more of the Convention rights?
• Has there been a difference of treatment between two persons who are in an analogous situation?
• Is that difference of treatment on the ground of one of the characteristics listed or other status?
• Is there an objective justification for that difference in treatment?

Applying this framework, the court determined that:

• The provisions in question fall within the ambit of Article 8 (right to respect for private and family life) and A1P1 (protection of property rights) of the ECHR.
• The appellant's situation, evolving from widowhood to cohabitation and subsequent remarriage, does not align analogously with those widows who remain single and non-cohabitating, especially considering the different economic and social dynamics involved.
• The differential treatment is based on the appellant's new marital status, an "other status" under Article 14, which includes characteristics beyond those explicitly listed.
• The legislative provisions are justified as they pursue legitimate aims of equitable distribution of finite public funds and ensuring that WPA targets those in balanced need without undue public expenditure.

Importantly, the court emphasized that the existing policy was rational, fair, and balanced, and adequately proportional to its intended aims. The suspension and termination of WPA were deemed reasonable responses to the changing circumstances of the recipient, ensuring that support is directed where it is most needed.

The Judgment in Lennon v Department for Social Development has significant implications for future cases and the broader legal landscape concerning social security and human rights:

• Affirmation of Legislative Discretion: The court reiterated that social security measures, especially those related to the allocation of finite public funds, are within the legitimate discretion of the legislature, provided they serve rational and equitable purposes.
• Clarification on Analogous Situations: The judgment underscores the necessity for claimants to demonstrate clear analogies when alleging discrimination, particularly in complex social and familial contexts.
• Reinforcement of Article 14 Framework: By meticulously applying the Stott questions, the court provided a robust template for evaluating future discrimination claims under Article 14, emphasizing the intertwined nature of different Convention rights.
• Children's Welfare Consideration: Although the appellant argued that the differentiation affected her child, the court maintained a balanced approach, ensuring that changes in parental circumstances are assessed within the wider context of family welfare and public funding allocation.

Overall, this judgment serves as a precedent that balances individual rights with public policy aims, ensuring that social security provisions are applied fairly without undermining the principles of non-discrimination.

Article 14 of the ECHR

Article 14 prohibits discrimination by ensuring that the rights and freedoms outlined in the Convention are enjoyed without discrimination on various grounds, such as sex, race, or other statuses. In this case, the relevant status pertains to the appellant's marital and cohabitation circumstances.

Ambit

"Ambit" refers to the scope or range within which the Convention rights apply. Determining whether the circumstances fall within the ambit of Article 14 involves assessing if the particular right, like WPA, is protected under the Convention's provisions.

Analogous Situations

For a discrimination claim to succeed, the claimant must demonstrate that their situation is analogous or similar to others who have been treated differently. This comparison helps establish whether the differential treatment is unjustified.

Objective Justification

This concept examines whether the government's differential treatment is based on a legitimate aim and if the means employed to achieve that aim are appropriate and proportionate. It ensures that any discrimination is not arbitrary but serves a valid public interest.