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In page Re Fong Thin Choo:
"All these worries point to the need for a stringent test to be set out and applied, and it has been suggested that such a test is already available in the form of the four "burdensome" requirements laid down in E v. Home Secretary. Not only are the four requirements difficult to establish (which would allay the concerns about a flood of litigation and the principle of finality), they also provide a guiding framework as to what merits judicial review based on an error of material fact.[6]
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