Summary: Mrs X complains about the Council’s failure to renew her Blue Badge, despite there being no change in her circumstances. We found the Council to be at fault because it was unable to demonstrate it carried out a proper assessment of Mrs X’s disabilities. This left Mrs X uncertain as to whether her application was properly considered. To remedy this injustice, the Council will apologise and reconsider her application. It will also take action to improve its service.

The complaint

1. Mrs X complains about the Council’s failure to renew her Blue Badge, despite there being no change in her circumstances. Mrs X says she has held a Blue Badge for six years and the Council's decision has increased her anxiety. Mrs X wants the Council to issue her with a Blue Badge.

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The Ombudsman’s role and powers

2. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused significant injustice, or that could cause injustice to others in the future we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
3. If we are satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(1), as amended)

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How I considered this complaint

4. I considered evidence provided by Mrs X and the Council as well as relevant law, policy and guidance.
5. Mrs X and the Council had an opportunity to comment on my draft decision. I considered any comments before making a final decision.

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What I found

Relevant law, guidance and policy

Blue Badges

6. The Department for Transport’s (DfT) Blue Badge Scheme helps people with severe physical mobility problems, or other conditions affecting their mobility, to access goods and services. It does this by allowing them, or their carer, to park near their destination. The scheme gives parking concessions to Blue Badge holders. Councils are responsible for the day-to-day administration and enforcement of the scheme. This includes assessing applicants’ eligibility for the badge.
7. Since August 2019 the guidance (the Guidance) has included the introduction of assessment criteria for people with severe mobility problems caused by non-visible (‘hidden’) disabilities.
8. The Guidance sets out what assessors may wish to consider when assessing a person’s mobility. The guidance is non-statutory. This means councils do not have to follow it, but most councils do. We expect councils to explain if they decide not to follow such guidance.
9. The Guidance says councils must make sure they only issue badges to residents who satisfy one or more of the criteria set out in legislation.
10. There are two types of eligibility criteria:
1. where a person is eligible without further assessment, they will receive a Blue Badge.
2. where a person is eligible subject to further assessment, they have to fulfil one or more of three criteria to qualify for a badge. They must:

• drive a vehicle regularly, have a severe disability in both arms and be unable to operate, or have considerable difficulty operating, all or some types of parking meter; or
• have been certified by an expert assessor as having an enduring or substantial disability, which causes them, during the course of a journey, to be unable to walk or experience very considerable difficulty walking, which may include very considerable psychological distress; or
• be at risk of serious harm when walking or pose a serious risk of harm to any other person.

11. If an applicant is unhappy with the outcome of an assessment, they may ask the council to review the decision.

12. The Guidance strongly recommends that every applicant who is refused a badge should be given a detailed explanation of the grounds for refusal. It is insufficient to simply state the applicant did not meet the eligibility criteria.

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What happened

13. Below is a summary of key events. It is not meant to show everything that happened.
14. Mrs X has been diagnosed with hearing loss. She has anxiety and depression and suffers from dizzy spells. She has had a Blue Badge for several years.
15. In July 2025, Mrs X applied to have her Blue Badge renewed. Mrs X said she had hearing loss in both ears, could not hear people approaching and got dizzy when she ran. She explained that with a Blue Badge she could park in the staff car park, park closer to her destination and would not need to walk where other cars were around her, which would help alleviate her anxiety.
16. The Council completed a desktop assessment and refused Mrs X’s application.
17. Mrs X requested a review of this decision. In support of her appeal, she provided copies of letters from her consultant and GP confirming her hearing loss. The Council said that deafness was not an automatic eligibility for a Blue Badge and asked Mrs X for other evidence. Mrs X responded and provided further documents which showed a primary diagnosis of hearing loss, dizziness and giddiness. Mrs X provided a letter from her GP which said she had been referred for dizziness and balance problems in 2022.
18. Mrs X’s appeal was unsuccessful. The Council’s decision letter to Mrs X stated “…after further consideration and examination of the evidence provided and the assessment, the Manager has now taken the decisions that unfortunately you do not qualify for a Blue Badge”
19. Mrs X complained to the Council. She said she had held a Blue Badge since 2019 and was successfully renewed in 2022. Mrs X said her disability had not changed. She also said the appeal decision letter did not provide any form of explanation as to why her application was unsuccessful. Mrs X said she had been struggling with depression and anxiety and had taken medication for several years.
20. The Council responded to Mrs X and said it had reviewed the documents provided with the application and the complaint. The Council said there was no evidence to support the required criteria, and it would not issue a Blue Badge. It said should Mrs X’s condition deteriorate, she should reapply and provide further medical evidence.
21. Mrs X remained unsatisfied and asked the Council to escalate her complaint. She said the Council had failed to consider that she was at risk near other vehicles. Mrs X explained she was almost run over in a car park as she had not heard an approaching vehicle. Mrs X said she was at risk in car parks and while crossing roads and was unable to move quickly due to dizziness. She said the Council’s decision had increased her anxiety.
22. The Council said the evidence Mrs X provided did not specify any difficulty with walking or mobility. It said impaired hearing was not an automatic reason for awarding a Blue Badge. The Council referenced Mrs X’s dizzy spells and anxiety and said should she provide medical evidence to support this, she could resubmit her application.
23. The Council acknowledged the decision not to renew Mrs X’s Blue Badge was inconsistent with the decision previously made to grant her badge and subsequent renewal. The Council explained the first Blue Badge was issued when hidden disabilities had first been introduced as a criteria, and the guidance was not as specific as it was now. The Blue Badge renewal was issued during the Covid-19 pandemic, when most badges were reissued as further assessments could not be carried out.
24. Disappointed by this outcome, Mrs X brought her complaint to the Ombudsman.

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Analysis

25. The Ombudsman’s role is not to decide whether Mrs X is eligible for a Blue Badge or give a view about the degree to which she meets the relevant criteria. Our role is to consider whether the Council followed the correct process in coming to a decision.
26. The Council has confirmed to the Ombudsman there are no written records about its decision making.
27. The Council has not provided a copy of the desktop assessment it completed to decide Mrs X’s application. Without this evidence, I am unable to determine whether the assessment was completed in accordance with the guidance and whether it considered the evidence Mrs X had provided. This is fault.
28. The Council has also not provided a copy of the decision letter it sent to Mrs X. Therefore, there is no evidence to show whether the Council clearly explained the reasons why she did not qualify for a Blue Badge. Further, the Council’s decision letter to Mrs X following her appeal provided no rationale for its decision and simply stated Mrs X did not qualify. This is fault.
29. The guidance strongly recommends that every applicant who is refused a Blue Badge should be given a detailed explanation of the grounds for refusal and it is not enough to simply state the applicant did not meet the eligibility criteria. This was particularly important in this case because Mrs X had been a Blue Badge recipient for several years. It is my view she had a reasonable expectation for the Council to explain why she was no longer eligible when her needs had not changed. Mrs X told the Council that her previous successful management of travel-related anxiety was related to her having had the benefit of a Blue Badge for several years.
30. I am satisfied the faults above have left Mrs X with uncertainty about whether her application was properly considered. This is injustice that requires a remedy.

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Action

31. Within four weeks of the final decision the Council will take the following action:
1. apologise in writing to Mrs X.
2. reconsider Mrs X’s application and provide a detailed explanation for its decision.
3. remind relevant staff that they should retain records of assessments and decision letters.
32. The Council should provide us with evidence it has complied with the above actions.

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Decision

33. I find fault causing injustice to Mrs X. The Council has agreed to our recommendations to remedy the injustice.
34. I have completed my investigation on this basis.

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Investigator's decision on behalf of the Ombudsman