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eflash archive 2007

The following eflashes have been archived as they were published during 2007. For our recent eflashes, please visit our main eflash page or click here to return to the archive.

288 Green and Coyne v Croydon LBC
[2007] EWCA Civ 1367
December 2007

The Court of Appeal has declined to rule on whether – as a matter of principle – a local housing authority making inquiries into a homelessness application pursuant to Pt.7, Housing Act 1996, are never obliged to go behind a decision of a court in possession proceedings which led to the applicant becoming homeless.
2007 download (pdf)
287 Accent Peerless Limited v Kingsdon
[2007] EWCA Civ 1314
December 2007

The Court of Appeal has held that an outright possession order was properly made against joint assured tenants on the ground of nuisance to their neighbours even though they were suffering from mental health problems and their behaviour had significantly improved after they were served with a notice of seeking possession.
2007 download (pdf)
286 Waltham Forest London Borough Council v (1) Maloba (2) The Law Society[2007] EWCA 1281
December 2007

The Court of Appeal has held that in deciding whether it is reasonable for an applicant “to continue to occupy accommodation” under s.175(3), Housing Act 1996, an authority is not limited to considering accommodation which he actually occupies at the time of his application. In addition, the Court rejected an argument that where an authority’s decision is quashed on appeal any costs order against them should be stayed pending the result of the authority’s fresh decision.
2007 download (pdf)
285 Hastoe Housing Association Ltd. v Ellis
Court of Appeal
November 2007

The Court of Appeal has held that a county court has power to accept an undertaking as part of an order adjourning possession proceedings under s.9, Housing Act 1988.
2007 download (pdf)
284 Couronne v Crawley BC, Secretary of State for Work & Pensions, First Secretary of State Bontemps v Secretary of State for Work & Pensions, West Sussex CC, Reigate and Banstead BC
November 2007

The Court of Appeal has held that the Secretary of State’s decision not to exempt British citizens of Chagossian origin from the habitual residence test in deciding whether they were eligible for jobseeker’s allowance and assistance under Pt 7, Housing Act 1996, was not irrational. The application of the habitual residence test was not discriminatory under either the Race Relations Act 1976 or the European Convention on Human Rights.
2007 download (pdf)
283 Wandsworth London Borough Council v Randall
[2007] EWCA Civ 1126
November 2007

The Court of Appeal has held that where an authority seek possession against a secure tenant under ground 16, Sch.2, Housing Act 1985 (under-occupation following succession), the question of what alternative accommodation is suitable for the tenant is determined by the composition of the tenant’s family as at the date of the hearing rather than as at the date of the succession.
2007 download (pdf)
281 Sandwell Metropolitan Borough Council v Hensley
Court of Appeal
November 2007

The Court of Appeal has held that an outright possession order should have been made against a secure tenant who had been convicted of being involved in large-scale cultivation of cannabis in his home.
2007 download (pdf)
280 R (Gilboy) v Liverpool City Council and Secretary of State for Communities and Local Government (interested party)
[2007] EWHC 2335 (Admin)
October 2007

The High Court has held that the procedure for review of a local authority’s decision to bring possession proceedings against a demoted tenant provided by the Demoted Tenancies (Review of Decisions) (England) Regulations 2004 (SI 2004/1679) is compatible with Art. 6, European Convention on Human Rights (right to a fair hearing).
2007 download (pdf)
279 Harouki v Kensington & Chelsea Royal London Borough Council
[2007] EWCA Civ 1000
October 2007

The Court of Appeal has held that an authority are entitled to decide that it is reasonable for a person who applies as homeless under Pt 7, Housing Act 1996, to remain in their current accommodation, notwithstanding that by so remaining the applicant commits an offence under Pt 10, Housing Act 1985.
2007 download (pdf)
278 Holmes-Moorhouse v Richmond-upon-Thames LBC
Court of Appeal
October 2007

A shared residence order granted in family proceedings is not determinative as to whether a dependent child might reasonably be expected to reside with a homeless person so as to confer on him priority need for accommodation under s.189(1)(b), Housing Act 1996. There is, however, a distinction between shared residence orders obtained by consent and those made following a contested hearing: where there has been a contested hearing, there will be no room for fresh consideration by the authority of the reasonableness of an applicant’s expectation that a child will reside with him unless there has been an intervening change of circumstances; where the order is made by consent, however, an authority must consider the matter for themselves.
2007 download (pdf)
277 R (Shrewsbury & Atcham BC and Congleton BC) v Secretary of State for Communities and Local Government
Administrative Court
[2007] EWHC 2279 (Admin)
October 2007

The High Court has held that the Secretary of State was entitled to conduct a process for the reorganisation of local government, and take final decisions as to the creation of new unitary authorities and the abolition of existing authorities, using common law powers derived from the Crown’s status as a legal person and in anticipation of the passage into law of a Bill, in place of the current statutory powers for reorganisation prescribed by the Local Government Act 1992.
2007 download (pdf)
276 R (N) v Lambeth LBC
[2007] EWHC 3427 (Admin)
September 2007

Where a failed asylum-seeker applies for assistance under s.21, National Assistance Act 1948, the local authority must consider whether the applicant’s need for care and attention is to any material extent made more acute by circumstances other than mere lack of accommodation and funds. The authority failed to address this question because their
assessment of the applicant’s needs on was merely based on the general criteria which they applied in deciding whether an applicant was eligible for community care services.
2007 download (pdf)
275 Lewisham London Borough Council v Malcolm
[2007] EWCA Civ 763
August 2007

The Court of Appeal has held that where a local authority seeks possession against a disabled person who has lost security of tenure under the Housing Act 1985 for a reason relating to that disability the court must dismiss the claim for possession if satisfied that the claim is unlawful under the Disability Discrimination Act 1995.
2007 download (pdf)
274 Andrews v Cunningham
[2007] EWCA Civ 762
August 2007

The Court of Appeal has held that providing a tenant with a rent book on the front of which the words “Assured Tenancy” appear does not constitute giving notice under Housing Act 1988, Sch.2A, para.1, that the tenancy will not be a shorthold tenancy.
2007 download (pdf)
273 The Houses in Multiple Occupation (Certain Converted Blocks of Flats)(Modifications to the Housing Act 2004 and Transitional Provisions for Section 257 HMOs) (England) Regulations 2007 No. 1904(“the Modifications Regulations”)
The Licensing and Management of Houses in Multiple Occupation (Additional Provisions) (England) Regulations 2007 No. 1903 (“the Additional Provisions Regulations”)
August 2007

The Secretary of State has made Regulations governing HMOs which are “converted blocks of flats”. The effect of the Regulations is to bring such HMOs within the licensing regime under Pt 2, Housing Act 2004, with effect from October 1, 2007. In addition, with effect from that date, duties are imposed in relation to management of such blocks.
2007 download (pdf)
272 Ahmed v Leicester City Council
Court of Appeal
June 2007

The Court of Appeal has held that, when determining whether it is reasonable for a homeless applicant to accept accommodation offered under s.193(7), Housing Act 1996, an authority are not required to put themselves into the applicant’s position, nor are they restricted to considering information which the appellant knew or ought to have known at the date of refusal.
2007 download (pdf)
271 R.(Abdi) v Lambeth LBC
Queen’s Bench Division
June 26, 2007

The High Court has held that it is lawful for a local authority officer, who has determined an applicant’s application for housing assistance pursuant to s.184, Housing Act 1996, also to determine that applicant’s request for interim accommodation pending review under s.188(3).

David Carter of Arden Chambers appeared for the London Borough of Lambeth.
2007 download (pdf)
270 YL v Birmingham CC and others
[2007] UKHL Civ 27

The House of Lords has held that a private provider of residential accommodation in a care home by arrangement with a local authority pursuant to s.21(1), National Assistance Act 1948, is not a public authority for the purposes of the Human Rights Act 1998.

Andrew Arden QC and David Carter of Arden Chambers appeared for Birmingham Council.
2007 download (pdf)
269 R (on application of Heffernan) v Rent Service
[2007] EWCA civ 544

The Court of Appeal has held that a rent officer was entitled to decide that the whole of Sheffield constituted the relevant “locality” when determining the local reference rent on an application for housing benefit by a tenant who lived in central Sheffield.
2007 download (pdf)
268 Islington London Borough Council v Honeygan-Green
Queens Bench Division
[2007] EWHC 1270
25 May 2007

The High Court has held that, where a secure tenant applies to exercise the right to buy but then becomes a tolerated trespasser, the right to buy application ceases to be effective and that application is not revived if the secure tenancy is subsequently revived by a court order.
2007 download (pdf)
267 Howard De Walden Estates Ltd v Aggio Earl Cadogan and Cadogan Estates Ltd v 26 Cadogan Square Ltd
Court of Appeal
[2007] EWCA Civ 499

The Court of Appeal has held that a head-lessee of a building containing flats does not have the right under Pt 1, Ch. 2, Leasehold Reform, Housing and Urban Development Act 1993, to an extended lease of a flat in the building.
2007 download (pdf)
266 R. (Kilby) v Basildon District Council
Court of Appeal
[2007] EWCA Civ 479

The Court of Appeal has held that a clause in a local authority’s secure tenancy agreement which purported to prevent the authority from changing the terms of that agreement without the agreement of a body of tenants’ representatives was ultra vires.
2007 download (pdf)
265 Birmingham City Council v Walker
House of Lords
[2007] UKHL22
16 May 2007

The House of Lords has held that where one joint tenant died before the date on which Ch.2, Pt 1, Housing Act 1980, came into effect (October 3, 1980), and the surviving joint tenant became the sole tenant, the surviving joint tenant was not a successor for the purposes of s.88(1), Housing Act 1985.
2007 download (pdf)
264 Elrify v City of Westminster Council
Court of Appeal
[2007] EWCA Civ 255

The Court of Appeal has held that a local authority’s decision that it was reasonable for a family to continue to occupy accommodation was flawed because the decision was based on an incorrect calculation as to the level of overcrowding in the flat under Pt 10, Housing Act 1985.
2007 download (pdf)
263 White v Knowsley Housing Trust, Secretary of State for Communities and Local Government intervening
Court of Appeal
2 May 2007

The Court of Appeal has held (for differing reasons) that the standard form N28 “suspended” possession order terminated an assured tenancy on the date given in the order, with the consequence that tenants against whom such orders had been made but who remained in occupation had become tolerated trespassers. It was open to a court, in order to avoid that
consequence, to make a “postponed” possession order in relation to an assured tenancy, but CPR 55 PD, Pt IV should be urgently amended so as to include assured tenancies.
2007 download (pdf)
262 Riverside Housing Association Limited v White & another
House of Lords
[2007] UKHL 20

The House of Lords has allowed Riverside Housing Association’s appeal against the Court of Appeal’s decision that their rent increase notices were invalid (see [2005] EWCA Civ 1385; e-flash 216). The tenancy agreement provided that the “rent payable will be increased annually with effect from the first Monday of June each year.” Their Lordships said that on a correct construction of the tenancy agreement, it was open to Riverside to increase the rent with effect from any date later than the first of June, provided it first gave 28 days notice.
2007 download (pdf)
261 London & Quadrant Housing Trust v Ansell
Court of Appeal
[2007] EWCA Civ 326

The Court of Appeal has held that where a tolerated trespasser pays off the rent arrears and costs so as to render a postponed possession order unenforceable by warrant, it is not an abuse of process for the landlord to bring fresh proceedings for possession.
2007 download (pdf)
260 Blackburn-Smith v Lambeth London Borough Council
[2007] EWHC 767 Admin

The High Court has reiterated that s.17 Children Act 1989 does not impose a duty on local authorities to provide accommodation for children in need. S.20 Children Act 1989 imposes a duty to provide accommodation to children in need but it does not impose a duty to house children and parents together.
2007 download (pdf)
259 Butlands v Powys City Council
Administrative Court
March 15, 2007

The Administrative Court has held that a request to a local authority by a person that correspondence be sent to him at a specified address did not amount to the provision of an address at which the authority could serve an abatement notice on him under the Environmental Protection Act 1990.
2007 download (pdf)
258 Brown’s Operating System Services Ltd v Southwark Roman Catholic Diocesan Corporation      
Court of Appeal
[2007] EWCA Civ 164

The Court of Appeal has held that where service charges are payable under a lease of commercial premises, in the absence of express provision for a reserve fund, there is no presumption that the landlord is entitled to retain any sums paid on account at the end of the lease. Whether or not the tenant should be reimbursed is purely a matter of construction of the lease.
2007 download (pdf)
257 West v Newham LBC     
Court of Appeal
22 February 2007

The Court of Appeal has held that the fact that a district valuer includes a parcel of land within the demise of a property when calculating the value of the property for the purposes of the right to buy does not exclude the county court’s jurisdiction to determine what property is comprised in the demise.
2007 download (pdf)
256 R (Lin) v Barnet LBC    
Court of Appeal
[2007] EWCA Civ 132
22 February 2007

The Court of Appeal has held that a housing allocation scheme did not operate unlawfully as regards the preference secured for the homeless and those owed the principal homelessness duties. The scheme failed, however, properly to explain when and for how long certain points were awarded to homeless applicants in temporary accommodation.
2007 download (pdf)
255 Johnson v Havering LBC, the Secretary of State for Constitutional Affairs and the National Care Association.
YL v Birmingham CC, Southern Cross Healthcare, OL, VL and the Secretary of State for Constitutional Affairs.    
Court of Appeal
[2007] EWCA CIV 26

The Court of Appeal has held that a private provider of residential accommodation in a care home by arrangement with a local authority pursuant to s.21(1), National Assistance Act 1948, is not a public authority for the purposes of the Human Rights Act 1998.
2007 download (pdf)
254 Birmingham CC & Secretary of State for Communities and Local Government v Doherty    
[2006] EWCA Civ 1739
Tuckey, Carnwath and Neuberger L.JJ

There was a majority decision on all the issues determined by the House of Lords in Lambeth LBC v Kay; Price v Leeds CC [2006] UKHL 10; [2006] 2 AC 465; [2006] H.L.R. 22 (E-Flash 226).
2007 download (pdf)

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