Railway – Construction of railway. The claimants issued judicial review proceedings, challenging the defendant Secretary of State's decision to make safeguarding directions for phase 1 of the proposed High Speed Two railway (HS2). They contended that the safeguarding directions were unlawful as they had not been assessed under the regime for strategic environmental assessment. The Planning Court, in dismissing the application, held that the safeguarding directions were not a plan or programme which set the framework for future development consent of projects.