New approach to ‘special circumstances’ within the meaning of Article 4:84 of the General Administrative Law Act: significance for deviating from the administrative penalty policy

New approach to ‘special circumstances’ within the meaning of Article 4:84 of the General Administrative Law Act: significance for deviating from the administrative penalty policy 1000 674 SarisLaw

In a judgment of 26 October 2016, the Administrative Jurisdiction Division gave a new interpretation to the inherent power to derogate of Article 4:84 of the General Administrative Law Act (GAL). Circumstances that were taken into account when drawing up a policy rule can now also be special circumstances that may require deviation from the policy rule. In this blog post, we discuss what this new approach entails and what consequences it has in particular for punitive sanctions law.

The full blog post is written in Dutch.

Date: 2 December 2016
ECLI: ECLI:NL:RVS:2016:2840
Author: Christien Saris