R v CHAYTOR & ORS (2010)

In considering whether actions outside the Houses and committees fell within parliamentary proceedings because of their connection to them, it was necessary to consider the nature of that connection and whether, if such actions did not enjoy privilege, that was likely to impact adversely on the essential business of Parliament. On that approach, the submission of claim forms for allowances and expenses did not qualify for the protection of privilege. Scrutiny of claims by the courts would have no adverse impact on the essential business of Parliament; it would not inhibit debate or freedom of speech or indeed any of MPs' various activities affecting their parliamentary duties. Similarly, expressions of parliamentary views of the ambit of art.9 did not support the suggestion that submitting such claims constituted parliamentary proceedings for art.9 purposes.

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