In "R v Hambleton DC ex p Somerfield Stores Ltd", in late 1998, the court ruled that PPG6 did not require a demonstration of need at planning application stage. In February 1999, Richard Caborn, the then Planning Minister, rebuffed this statement and confirmed that demonstration of need was required. Considers this policy statement and its application to retail development. Also deals with the following issues: the place of policy in planning decisions; the extent to which qualitative retail matters (including competition between retailers) are a material consideration, and thus whether a challenge could be made on the basis that immaterial considerations should be taken into account; whether any decision-maker could be found to have made an irrational decision on whether there is a need for a store when 'need' is not defined, and whether the review of such a decision could be insufficient under the Human Rights Act 1998 [Partly taken from journal headnote].