One of the most important decisions in this area is Roy v Kensington and Chelsea and Westminster Family Practitioner Committee (FPC) [1992] 1 AC 624. Dr Roy was a GP carrying out work for the NHS. Payment for his services was provided for under statutory regulations. The FPC was entitled to reduce the amount of payment if they considered that a GP was not devoting a substantial amount of time to his NHS work. The FPC took the view that Dr Roy was not doing so and therefore reduced his practice allowance by 20 percent. Dr Roy brought a private action against the FPC claiming inter alia that the Committee was in breach of contract. The FPC applied to strike out his claim as an abuse of process. According to the FPC, the correct procedure for challenging their decision was by way of an application for judicial review.