Real Estate Bulletin – Autumn 2018
A welcome from the editor….
Welcome to the autumn edition of the Real Estate Bulletin. This quarter, we look at cases involving assets of community value, town and village greens, exceptions to business rates, abandoning easements (or not, as the case may be), oral variations to written contracts, relief from forfeiture under a licence, rights of reverter and how much compensation a homeowner might get to cover damage caused by mining subsidence. For landlords and tenants, we look at cases involving serving notices under an agreement for lease, landlord’s consent to a tenant’s planning application, payment of rent where a tenant has entered into a CVA and a couple of cases on the horizontal extent of the demise in a lease: one relating to airspace, one relating to subsoil. The planning points cover the meaning of ‘mast’ in the context of electronic communication apparatus and the impact of a clerical error in a planning permission.
The Bulletin brings together highlights from our popular quarterly update training sessions, so if you are local to the East Midlands or pass through every now and again and would like details of our next event in December, please get in touch.
CASE LAW UPDATE
Development – assets of community value: Banner Homes Ltd v St Albans City & District Council & Anr
- Assets of Community Value (ACVs) where introduced by the Localism Act 2011
- Community groups have the right to bid for and buy local land that is considered to have community value – i.e. its actual current use furthers the social wellbeing and interests of the local community and it is realistic to think that the land can continue to be used to further such wellbeing and interests
- The actual use does not have to be lawful
- Once land is listed as an ACV, the landowner is restricted from disposing of it for a period of time. Land will be listed for a period of five years, during which the restrictions on sale apply
We’ve been tracking this case since back in 2015. Readers may recall that B owned a field in the green belt that it wanted to develop for housing. Local residents had used the field for recreational purposes for a number of years, including deviating from the two formal footpaths across the field when walking their dogs, playing etc.
The field was listed as an ACV in March 2014 and in September 2014, B put up wire fencing along the length of both footpaths. B also appealed against the listing, arguing that the local residents’ use of the field was a trespass (because they had strayed from the footpaths) and therefore couldn’t constitute ‘actual current use’ for the purposes of the Localism Act.
B’s appeal was dismissed by the First Tier Tribunal…and the Upper Tribunal…and now by the Court of Appeal.
For a period of five years from the date of listing, if B wants to sell the land (which presumably it will once it has built the houses), it must give notice to the Council of its intention to sell. Community interest groups would then have six weeks to ask to be considered as a potential bidder, and if this happens, B will be prevented from selling the land to anyone else for a period of six months.
The consequences of listing are not as serious for developers as the designation of land as a town or village green, but the restrictions on sale can cause delay and inconvenience. We are seeing an increasing number of cases on ACV, although to date, these have related to more obvious assets such as pubs or other locally interesting buildings. The ACV legislation applies to open land as well. The fact that the use of the land by the community has been unlawful does not affect the ability to list it and this decision shows how those opposing development in an area can use the ACV regime to disrupt potential schemes.
If you would like further advice on all things ACV, please contact Mark Brown in our Milton Keynes office – firstname.lastname@example.org; (0845 271 6764). Mark has advised a number of clients on this topic, dealing with objections to nominations for listing on behalf of landowners, and conducting reviews of listing decisions and an appeal in the First Tier Tribunal. He can also assist with TVG issues, as detailed in the case below.
Development – town or village green: R (on the application of Cotham School) v Bristol City Council
- Registration of land as a town or village green (TVG) can be a serious problem for landowners as well as developers
- However, prohibitory signage could be the answer!
BCC owned land known as Stoke Lodge Playing Fields. Local sports clubs, along with CS, used the land as playing fields under arrangements agreed with BCC. However, members of the local community also used the land for (undocumented) recreational purposes.
An application was made for the land to be registered as a TVG on the basis that ‘a significant number of [local] inhabitants…[had] indulged as of right in lawful sports and pastimes on the land for…at least 20 years’.
The BCC inspector found that members of the public had used the land for a sufficient period of time, but that user had not been ‘as of right’, which is a key requirement of a successful TVG registration. User was not ‘as of right’ because at least three of the 12 access points to the land had signs saying ‘Members of the public are warned not to trespass on the playing field’ and inviting them to seek permission from BCC’s Director of Education. The inspector decided this made the public use contentious and he recommended the application for registration be rejected. BCC disagreed (they thought there were too few signs for such a large site) and went ahead and registered the land as a TVG anyway.
The decision was challenged in the High Court, which found that BCC had erred in law in registering the land as a TVG.
A useful case for landowners who want to prevent land being registered as a TVG – or indeed prevent private (prescriptive) rights arising over their land. Suitably worded signs, which are visible to and seen by local inhabitants make their use of the land contentious and not ‘as of right’. It is important, however, to ensure signs are maintained, kept clear of vegetation, repaired if damaged etc.
A less labour-intensive alternative would be to lodge a statutory statement in prescribed form with the relevant commons registration authority (usually the county council), which is deemed to end any period during which people have used the land for sports and pastimes and therefore prevent ‘as of right’ user. Be aware though that depositing such a statement creates a one year grace period within which applications for registration of a TVG can still be made based on recent ‘as of right’ user.
The decision is also a useful reminder for registration authorities that if they depart from the recommendations contained in an inspector’s report prepared after a non-statutory public inquiry, they need to give adequate and sufficient reasons for doing so.
Business rates – exceptions: Iceland Foods Ltd v Berry (Valuation Officer)
- The Valuation for Rating (Plant and Machinery) (England) Regulations 2000 state ‘service’ plant, such as air conditioning, is rateable unless it is ‘used or intended to be used in connection with services mainly or exclusively as part of manufacturing operations or trade processes’
- Although the Chancellor offered some help in the Autumn 2018 Budget, business rates are often cited as one of the reasons so many retailers are struggling, particularly on the high street
The air-handling system in the ratepayer’s retail warehouse was designed and programmed to maintain the warehouse temperature during trading hours at an acceptable level for both the functioning of refrigerated cabinets and the comfort of staff and customers.
The issue was whether the air-handling system fell within the exception in the Regulations: if it did, it would not be taken into account in calculating the rateable value of the premises.
Both the Upper Tribunal and the Court of Appeal found against the ratepayer, holding that ‘trade process’ meant a process that was designed to bring about a ‘transition’ from one state to another.
The ratepayer successfully appealed to the Supreme Court, which held that the proper interpretation was that a process indicated ‘anything done to goods or materials’ and a ‘trade process’ was simply a process carried on in the course of a trade.
This case is similar to another one that hit the headlines last year (Newbigin (Valuation Officer) v S J & J Monk (a firm)), where, as in this case, the Valuation Office Agency advanced arguments which differed from the contents of its own Rating Manual, and in each case, it was the Rating Manual approach, rather than the agency’s legal arguments, which the Supreme Court upheld
Where service plant, such as air conditioning, heating, ventilation etc is used mainly in conjunction with a trade process, it will not be rateable. Rating assessments for a number of commercial and retail properties include elements of value attributable to such items of plant and, in light of that, some ratepayers’ properties may have been overvalued. It’s worth consulting a specialist ratings surveyor for further advice.
Easements – abandonment: Annetts v Adeleye
- It is notoriously difficult to establish that an easement has been abandoned – even very long periods of non-use are not sufficient on their own
- It is a question of fact in each case
- Even where someone is physically prevented from exercising their rights, it doesn’t mean they’ve been abandoned
A property called Summerhill had the benefit of a right of way granted in 1962 over an access route on the adjoining property, known as Salterns.
In 1968, the owners of Summerhill sold a strip of land to a third party. In the transfer of that strip, the buyer covenanted with the seller to erect and forever after maintain a fence along the boundary between the strip and the access route.
The problem was that if the buyer of the strip complied with the fencing covenant, it would block off use of the access route.
The owners of Salterns said the right of way over the access route, which remember was on their property, had been abandoned when the fencing covenant was entered into, but the court disagreed.
It is a question of fact whether a person who owns land with the benefit of a right intends to abandon it – their conduct must have clearly demonstrated an intention that neither they, nor any successors in title, would make use of the right in the future.
A fencing covenant is a contractual arrangement and even though in this case it was expressed to apply forever, the parties to the contractual arrangement could agree to release the obligation at any time. The Court of Appeal took the view that the right of way was simply suspended for the duration of the fencing covenant and that the right could be used again if Summerhill and the strip of land came to be owned by the same person in the future.
Reverter – school sites: Rittson-Thomas & Ors v Oxfordshire County Council
- The School Sites Act 1841 provides that if someone (a grantor) conveys land to be used as a school site, ownership would revert to the grantor (or their successors) if the land ceased to be used as a school (right of reverter)
- However, the land can be sold or exchanged for another ‘more convenient or eligible site’ and the proceeds can be used to buy another site or improve other premises used for the purposes of a school
Land was conveyed in 1914 for the purposes of providing a school in Oxfordshire. In the early 2000s, OCC decided to relocate the school to a neighbouring site that it already owned. OCC spent money developing the site in order to accommodate the new school.
OCC stopped using the original site in February 2006 and relocated the pupils to the new school. The following September, OCC sold the original site, using the sale proceeds to cover some of the development costs.
The heirs of the person who had conveyed the land back in 1914 claimed that a reverter had been triggered in February 2006 when OCC stopped using the site as a school, because no exchange of land had taken place and the sale took place well after the original school had been closed. OCC’s argument was that it had defeated the reverter because it held ‘a firm and settled intention’ to sell the old site and use the sale proceeds to defray the costs it had incurred in improving its own site.
In 1987, the Reverter of Sites Act abolished the concept of ownership of the site reverting to the original grantor or their successors and substituted what is now a trust of land, meaning that the sale proceeds are held on trust for the grantor or their successors. In order to take free from the trust, anyone buying an old school site would need to pay the purchase price to two trustees or a trust corporation. A bigger issue is buying a site that is still being used as a school – any reverter trust will not yet have arisen, so if the school use ceases during the buyer’s ownership, they would hold the property on trust for the beneficiaries of the right of reverter.
Licences – oral variation: Rock Advertising Ltd v MWB Business Exchange Centres Ltd
- Contracts may contain no oral modification clauses
- Depending on the nature of the contract, parties should carefully consider the implications of restricting their ability to easily and quickly change the terms of their agreement in the future
R occupied managed office space in a building owned by M under a licence that contained a no oral modification (NOM) clause. The clause said ‘All variations to this licence must be agreed, set out in writing and signed on behalf of both parties before they take effect’.
R fell into arrears with its monthly licence fee and M served a notice to terminate the agreement. R claimed that one of its directors had come to an understanding, by way of an oral agreement with M’s credit controller, to reschedule the monthly licence fee payments. M denied that any such agreement had been made and that even if it had been, it wouldn’t be enforceable because of the NOM clause.
The Court of Appeal had decided that where no legal formalities existed for the creation of a contract, such that it could be made orally, parties were free to vary it orally and could therefore orally dis-apply the NOM clause. The case went all the way to the Supreme Court, which held that the law should give effect to a contractual provision requiring specified formalities to be complied with in order to vary the contract.
There are fewer formalities for licence agreements (although care needs to be taken not to inadvertently create a lease!), but the Supreme Court’s decision brought certainty where the Court of Appeal’s had not. Had the agreement been one relating to a land interest (such as a sale contract, for example), the same statutory requirements that apply to the creation of the contract would apply to any variation, i.e. in writing, incorporating all the terms and signed by or on behalf of both parties. There may be cases where a party has acted upon a variation and an estoppel has arisen, but generally, a NOM clause should operate according to its terms.
Licences – relief from forfeiture: General Motors UK Ltd v The Manchester Ship Canal Company Ltd
- Licences can grant possessory rights
- Licensees may be entitled to remedies more akin to those usually afforded to tenants
GM owned a car manufacturing plant adjacent to MSCC’s canal. In 1962, MSCC granted GM a licence to discharge surface water into the canal. The right was granted in perpetuity and GM agreed to pay an annual sum of £50.
In 2013, GM didn’t pay the £50 and MSCC terminated the licence. The parties then entered into negotiations for a new licence arrangement, but MSCC was seeking annual payments of over £500,000. GM decided to apply to the court for relief from forfeiture in respect of the termination of the original licence.
MSCC argued that the 1962 licence was just that – a personal licence that did not create any proprietary land rights in favour of GM – and therefore GM wasn’t entitled to relief. Both the High Court and the Court of Appeal disagreed. The Court of Appeal took the view that the licence conferred a possessory interest on GM, applying the established test of factual possession and intention to possess.
Relief from forfeiture is not confined to landlord and tenant situations – it is available as a remedy where proprietary or possessory rights are forfeited. Property owners should be careful to avoid granting rights that are possessory in nature. In this case, MSCC lost an opportunity to significantly increase its income from the licence arrangement.
Coal mining – subsidence: White v The Coal Authority
- Under the Coal Mining Subsidence Act 1991, the Coal Authority has a ‘remedial obligation’ in respect of subsidence damage
- The Coal Authority is required to put damage right so far as is ‘reasonably practicable’
W owned a farm and, in 2008, he demolished the old farmhouse and replaced it with a new house and also redeveloped a range of other buildings. The new house and the outbuildings suffered extensive cracking and tilted noticeably as a result of nearby coal mining operations in 2010 and 2011.
The Coal Authority admitted liability for the damage to W’s property so the only issue was quantum – how much was the Authority obliged to pay? The Authority accepted that it had to pay the cost of remedying the cracks but argued it wasn’t obliged to pay for the much more extensive (and expensive) work to correct the tilting of the buildings on the property.
The Upper Tribunal had to decide what works were ‘reasonably practicable’ to make good the damage. A case back in 2003 had established that remedial work is reasonably practicable if it is ‘feasible and not extravagant’. The parties agreed that the only way to make good the tilt was to demolish and rebuild the main farmhouse. Unsurprisingly, the Authority did not think this was reasonably practicable, but W did and the Tribunal agreed with him.
The cost of basic demolition and rebuilding in W’s schedule was just over £334,000 and with other potential items, would come to around £400,000. The value of W’s property without the damage was at least £1.455 million at the time, so demolition and reinstatement on a like-for-like basis would cost in the region of 27% of the value of the whole property.
Provided works are not deemed ‘extravagant’ in the context of the property in question, compensation for subsidence damage can include the cost of demolition and rebuilding.
LANDLORD AND TENANT ROUND UP
Agreement for lease – service of notices: Ropemaker Properties Ltd v Bella Italia Restaurants & Casual Dining Group Ltd
- It is important to comply with all contractual requirements, particularly those relating to notices
- This is the case even where the requirements have no apparent purpose or benefit!
B served notice to terminate an agreement for lease on the basis that the ‘Unconditional Date’ under the agreement had not occurred by the ‘Agreement Long Stop Date’. The relevant clause of the agreement (clause 14.2) provided, in such circumstances, that ‘…either the Landlord or the Tenant may at any time after the … Agreement Long Stop Date …give written notice to the other and the Guarantor to determine this Agreement’.
B served written notice on the landlord (R) to terminate the agreement on the basis that the long stop date had passed without the contract having become unconditional, but did not serve notice on its guarantor. The notice was held to be invalid and R subsequently waived the other conditions in the agreement that meant it became unconditional and that B was bound to complete!
When exercising unilateral rights under a contract, such as a right to terminate or an option to purchase, failure to comply with all the requirements of the relevant clause in the contract will mean the right has not been validly exercised. This can have serious consequences – here B had to take a lease it had resolved it did not want.
Change of use – unreasonably withholding consent: Rotrust Nominees Ltd v Hautford Ltd
- Landlords usually seek to restrict the ability of their tenants to do certain things at the property without landlord’s consent in order to protect either its value or its structural integrity
- Such restrictions are often qualified by a requirement for the landlord to act reasonably when considering an application for consent
We covered the County Court decision in this case back in 2017. H was the tenant of 51 Brewer Street, London W1 under a lease for a term of 100 years from 25 December 1985 at a peppercorn rent. The permitted use under the lease included residential use.
H sub-let the whole of the building, which has six floors, to R (a connected company). R used the basement and ground floors for its ironmonger business, the first and second floors for storage and the third and fourth floors for residential purposes.
R wanted to maximise income from the building, but in order to use the first and second floors for residential purposes, it needed planning permission for change of use. The headlease contained a tenant covenant ‘…not to apply for any planning permission without the prior written consent of the Landlord such consent not to be unreasonably withheld’. The superior landlord (RNL) refused consent arguing that it may facilitate a claim by H to acquire the freehold of the building under the Leasehold Reform Act 1967. This would damage the value of RNL’s investment portfolio (the Soho Estate).
The question was whether consent had been unreasonably withheld. The County Court said that the main purpose of the covenant in the lease was to protect RNL from any unwanted enforcement proceedings brought by the local planning authority and that RNL was in fact trying to achieve a collateral purpose, i.e. to impose a restriction that was contrary to the lease provisions. RNL appealed, but the Court of Appeal has dismissed RNL’s case.
Landlords should take note that if a lease requires a tenant to obtain consent to apply for planning permission, the landlord should only refuse consent where the reason(s) are associated with the purpose for which the restriction on planning applications was imposed, not to secure a collateral advantage.
By way of reminder, the County Court had accepted the argument that the purpose of the covenant was not to enable RNL to restrict or limit the permitted residential use under the lease. Another thing the Court took into account was the fact that the original tenant had paid a premium for the grant of the lease, as had H on taking an assignment. Those premiums would have been negotiated in light of the use to which the tenant would be entitled to put the property.
Company Voluntary Arrangement – administration expenses: Wright & Anr (Liquidators of SHB Realisations Ltd) v Prudential Assurance Company Ltd)
- A CVA is a mechanism that allows a company to settle its unsecured debts by paying only a proportion of the amount it owes to its creditors or to come to another arrangement with its creditors over payment
- It is a statutory contract that binds anyone who is entitled to vote on it (whether they did or not)
- There are very limited grounds for challenging a CVA
- CVAs have come back into fashion recently, particularly on the high street
In March 2016, BHS agreed a CVA with its creditors. The principal purpose of the arrangement was to reduce (by 75%) the rent payable in respect of certain BHS stores. It was a provision of the CVA that if the arrangement was terminated, the rent reduction would be deemed never to have happened and the affected landlords would be able to claim for the full rent that would have been due, less any payments made under the CVA.
The CVA did not provide that it would terminate automatically in the event of BHS’s administration, but did state that the landlords were entitled to terminate for non-payment of sums due under the CVA.
In April 2016, BHS went into administration and the administrators kept the stores open for a few months, paying reduced rents in accordance with the CVA, before folding the business and vacating the shops. BHS then stopped paying rent and in December 2016, one of its landlords terminated the CVA. BHS then went into liquidation.
The affected landlords then claimed that the full rent, that was now retrospectively payable in respect of BHS stores for the period of the administration, was payable as an expense of the administration. The question for the court was whether the landlords should be entitled to recover the full rent. The liquidators put forward various arguments, including that the provision allowing landlords to claim the full rent due was unenforceable because it was a penalty payable for breaching the CVA and it also breached the pari passu (or equality) principle of distribution because it favoured the landlords over other creditors. The liquidators also argued that the full rent due for the period of the administration did not accrue until the CVA was terminated, i.e. after the end of the administration, so it could not be an expense of the administration.
The court found against the liquidators.
Rent on leasehold premises that a company in administration continues to occupy for the purpose of the administration is payable as an administration expense. It is payable for the whole of the period during which the administrator retains possession of the property and is treated as accruing from day to day. It doesn’t matter that liability to pay a larger sum, as in this case, was not triggered until after the administrators had vacated the stores in question.
Administration expenses are payable in priority to all claims other than those of fixed charge creditors.
Extent of demise – airspace: Ralph Kline v Metropolitan and County Holdings Ltd
- For freehold land, ownership generally includes ownership of any buildings on the land, the subsoil beneath the surface of the land and the airspace above the land to a reasonable height
- The same does not apply to leasehold ownership, if the lease says something different
- The courts will try to interpret a lease to ascertain the intentions of the parties
A lease was granted in 1969 for a term of 120 years. The lease contained a detailed description of the area demised.
In 2001 the landlord granted an overriding lease of the same premises, described more widely this time as ‘land and buildings’. In 2015, the tenant of the overriding lease granted a lease of the airspace above the building to R. When R came to register its lease of the airspace, M (who was then the tenant under the 1969 lease) argued that the airspace was included in the 1969 lease so any lease granted to R was subject to the terms of M’s lease. The court agreed.
Airspace leases can be valuable assets if they carry with them sufficient rights to enable upwards development of the property. Where a building is already subject to a leasehold interest, it is important to check whether the airspace was excluded from that original lease. In this case, there was nothing in the 1969 lease to indicate that the demise was only of the internal parts of the buildings specified and some of the landlord’s reservations in the lease would not have made sense if the lease was of an internal only demise (for example, reserving mines and minerals). In addition, the tenant was obliged to decorate the outside of the premises.
Extent of demise – subsoil: Gorst v Knight
A house had been divided into two maisonettes; Flat 1 was on the ground floor and Flat 2 was on the first and second floors. Flat 1 included a small cellar.
G had a long lease of Flat 1 and obtained planning permission to make the cellar into a habitable space by digging down into the subsoil (as it wasn’t possible to raise the height of the cellar ceiling, there being a house on top!)
K, who was the freeholder of the building, and lived upstairs in Flat 2, opposed G’s plans, arguing that the subsoil was not included in G’s lease. The lease of Flat 1 demised all parts of the building below the midway line, including the structure and included an interpretation of the ground floor ‘maisonette’ which included ‘the foundations and the void or cellar below the ground floor’. K argued that the lease of Flat 1 did not include the subsoil and the court agreed.
As the subsoil was not demised, K, as landlord, had complete discretion as to whether to allow G’s extension to the cellar and, if so, on what terms, so presumably G will not be getting its subterranean living space.
Unlike in relation to freehold ownership, there are no legal presumptions as to the horizontal extent of leasehold ownership, so clear and precise drafting in the lease is crucial.
The treatment of subsoil, from a legal perspective, was different to the treatment of airspace for various reasons: the subsoil is key to the stability of the entire building – if the foundations become unstable, the structural integrity of the whole building is threatened; access to the subsoil is more difficult than accessing the airspace above a building; and the subsoil is not visible, so problems cannot be spotted so easily.
Permitted development – communications masts: R (Mawbey) v Lewisham Council
- The General Permitted Development Order 2015 (GPDO 2015) grants deemed planning permission for the installation, alteration or replacement of any electronic communications apparatus
- However, there are exclusions including where works relate to a mast on a building that is less than 15 metres in height and the mast would be within 20 metres of the highway
A social housing provider managed a property on behalf of LC and granted C a licence to install telecommunications apparatus on the roof of the property. The apparatus consisted of nine antennae supported by antennae poles and attached, by a yoke arm, to central support poles. These central poles were held in place by steep tripods bolted to concrete plinths. The apparatus was under 15 metres in height and was within 20 metres of the highway.
M asked LC to take enforcement action on the basis that the term ‘mast’ with the GPDO 2015 should be interpreted broadly and should include central support poles of the kind used in this case. LC refused to take action, deciding that support poles were not ‘masts’.
M applied for judicial review and was successful. The High Court found that LC had wrongly interpreted the relevant paragraph of the GPDO 2015 and that the equipment in question did not benefit from permitted development rights, so an express planning permission was required.
This is a noteworthy decision for both local planning authorities and telecommunications operators and gives an indication of how to interpret the word ‘mast’ in the GPDO 2015.
Planning permission – clerical error: R (on the application of Thornton Hall Hotel Ltd) v Wirral Metropolitan Borough Council
- Where a local planning authority has made a mistake in the exercise of its statutory planning powers, it is in the public interest for the court to be able to rectify that error
- Time limits in relation to planning enforcement are strict, but in some cases, there may be justification for bringing action out of time
TH owned Thornton Manor. THH owned the nearby Thornton Hall Hotel. Both venues host wedding events and other functions. TH applied to WMBC for planning permission to erect three marquees on its site.
The planning report recommended permission be granted, subject to certain conditions, including a condition that the permission be limited to a period of five years from the date of grant.
In December 2011, WMBC granted unconditional planning permission for the three marquees in the grounds of Thornton Manor. This was due to an unexplained error by one of the Council’s officers. TH was aware of this error, but chose to remain silent about it, not least because it has accepted events bookings up to 2020 on the basis of the unconditional planning permission!
THH discovered the error in favour of its competitor some five years later and applied to have the planning permission quashed. THH was successful.
A short point here: in cases of deception and concealment in planning enforcement, the courts will look to ensure no one benefits from an error by keeping quiet about it and hoping that the deadline for taking action, either by judicial review or enforcement, expires. Remember Mr Fidler and his hidden castle…?
The content of this page is a summary of the law in force at the present time and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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