Bennett, R (on the application of) v Copeland Borough Council

Bennett, R (on the application of) v Copeland Borough Council

A person cannot be a resident of a property for council tax purposes under section 6(5) of the Local Government Finance Act 1992 unless he has actually lived in it; ownership, intention to return, or lack of other property do not suffice without actual residence.

Parties
Claimant/appellant: George Bennett; Defendant/respondent: Copeland Borough Council
Jurisdiction
England and Wales
Judgment Date
14 May 2004
Procedural Posture
Judicial Review/statutory Appeal / Appeal From High Court to Court of Appeal
Outcome
Appeal allowed
Legal Topics
Council Tax Liability, Definition of Residence, Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

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Parties

George Bennett

Claimant/appellant

Copeland Borough Council

Defendant/respondent

Procedural Posture

Judicial Review/statutory Appeal / Appeal From High Court to Court of Appeal

  1. 1 Whether ownership of a property without actual residence can constitute 'sole or main residence' for council tax liability under section 6(5) of the Local Government Finance Act 1992
  2. 2 Whether the Tribunal and High Court erred in law by holding that factors other than actual residence could suffice for council tax liability

Ratio Decidendi

A person cannot be a resident of a property for council tax purposes under section 6(5) of the Local Government Finance Act 1992 unless he has actually lived in it; ownership, intention to return, or lack of other property do not suffice without actual residence.

Court Disposition

Appeal allowed

Orders

  • Appeal allowed with costs
  • Application for permission to appeal to the House of Lords refused