In January the Supreme Court heard the appeal in Westminster CC v SL, involving two important issues on the scope of s 21 of the NAA 1948: (1) whether a need for care and attention must be accommodation-related in order to give rise to accommodation pursuant to s 21, and (2) the meaning of “care and attention”, and specifically whether the need for monitoring and “watching-over” typical of many people with mild mental illnesses, come within s 21. Judgment is awaited.