In R (on the application of Blackpool Football Club Properties Limited and Owen John Oyston) v HMRC [2008] EWHC 710 (published 14 April 2008), the High Court refused permission to apply for judicial review of a decision to refuse Enterprise Investment Scheme relief. The application was based on a representation allegedly made by the director general of HMRC in the course of negotiations to the effect that relief would be granted in certain circumstances, which, the applicants argued, created a legitimate expectation that relief would be granted in those circumstances. The court concluded that there was no legitimate expectation that had not been met and that the claimants had an alternative remedy.