The Supreme Court of the United Kingdom dealt with the application of the Carltona doctrine in "R v Adams", 2020 UKSC 19. In 1973, Gerry Adams, an Irish politician, was detained without trial by an interim custody order made under Article 4 of the Detention of Terrorists (Northern Ireland) Order 1972. It was later revealed that the Order required the Secretary of State to have considered the matter personally. Adams challenged the validity of the decision, arguing that the Secretary of State had failed to do so. The issue before the Supreme Court was whether the Carltona principle operated to permit the making of such an Order by a Minister of State (para 8). Lord Kerr, delivering a unanimous judgment, held that the wording of the 1972 Order was clear to exclude the application of the Carltona doctrine (paras 31-32). Besides, in light of the seriousness of the consequences of the decision, the decision ought to be made by the Secretary of State personally (para 38). There was also no evidence that it would create an undue burden on the Secretary of State (para 39).