One of the most significant cases in this area, X v Bedfordshire County Council [1995] 3 All ER 353 provides an example of how difficult it can be to determine this issue. The case itself concerned five separate claims against a local authority for negligence; two cases concerned child abuse, the other three concerned educational provisions for special needs pupils. The House of Lords rejected the child abuse claims as it would not be just and reasonable to impose such a duty in an area where a degree of discretion is required and where there are differing opinions on the practice to follow. There were also alternative means by which such persons may bring a claim, eg judicial review actions. In the education cases, the Lords were of the opinion that it was arguable that a duty of care may exist. Here the advice given was made directly to the parents who relied on it.