Engagement should begin early in policy development when the policy is still under consideration and views can genuinely be taken into account.

Every effort should be made to make available the evidence base at an early stage to enable contestability and challenge.

108. It is common ground that, whether or not consultation of interested parties and the public is a legal requirement, if it is embarked upon it must be carried out properly. To be proper,

• consultation must be undertaken at a time when proposals are still at a formative stage;
  
• it must include sufficient reasons for particular proposals to allow those consulted to give intelligent consideration and an intelligent response;
  
• adequate time must be given for this purpose;
  
• and the product of consultation must be conscientiously taken into account when the ultimate decision is taken ( R v Brent LBC ex parte Gunning [1986] 84 LGR 168).