ne of the features of environmental legislation is the need for the government to write plans and strategies about how it will achieve certain targets.  How they will reach them is a matter of discretion, in which the courts will rarely interfere.  But we saw with the litigation about the Air Quality targets (culminating in R. (on the application of ClientEarth) v Secretary of State for the Environment, Food and Rural Affairs [2015] UKSC 28) and the Climate Change strategy (Friends of the Earth and others v Secretary of State for Energy Security and Net Zero [2024] EWHC 995 (Admin)) that the courts are prepared to hold the public authorities to account if they don’t produce a strategy document that actually answers the questions about how the targets may be met.  Now it is the turn of water – the generic measures included in the numerous river basin management plans (RBMP) have not passed muster.  The Secretary of State was hoping that a RBMP be a strategic, high-level document setting a direction of travel for a river basin district as a whole. The Court of Appeal has rejected that interpretation, and has upheld the initial High Court decision by Lieven J in Secretary of State for Environment, Food & Rural Affairs v R. (on the application of Pickering Fishery Association) [2025] EWCA Civ 378 (2 Apr 2025).  It is also notable that the OEP used its powers to intervene, and submitted that the judgment of Lieven J was correct.