Save Greater Manchester Green Belt Limited v Secretary of State for Housing, Communities and Local Government & Ors

The Inspectors did not err in law by adopting an unduly restrictive legal test for 'exceptional circumstances' when considering additions to the Green Belt. They lawfully used criteria such as fundamental change in circumstances and boundary anomalies as relevant considerations, but also considered other circumstances, and exercised their planning judgment in accordance with established legal principles. The claim is dismissed.

Parties: Claimant: SAVE GREATER MANCHESTER GREEN BELT LIMITED; First Defendant: SECRETARY OF STATE FOR HOUSING, COMMUNITIES AND LOCAL GOVERNMENT; Second Defendant: GREATER MANCHESTER COMBINED AUTHORITY; Third Defendant: BOLTON COUNCIL; Fourth Defendant: BURY COUNCIL; Fifth Defendant: MANCHESTER CITY COUNCIL; Sixth Defendant: OLDHAM COUNCIL; Seventh Defendant: SALFORD CITY COUNCIL; Eighth Defendant: ROCHDALE BOROUGH COUNCIL; Ninth Defendant: TAMESIDE METROPOLITAN BOROUGH COUNCIL; Tenth Defendant: TRAFFORD COUNCIL; Eleventh Defendant: WIGAN COUNCIL; First Interested Party: WAIN ESTATES (CARRINGTON) LIMITED; Second Interested Party: WAIN ESTATES (LAND) LIMITED; Third Interested Party: PEEL L&P INVESTMENTS (NORTH) LIMITED; Fourth Interested Party: RLUKREF NOMINEES (UK) ONE LIMITED; Fifth Interested Party: RLUKREF NOMINEES (UK) TWO LIMITED
Jurisdiction: England and Wales
Judgment Date: 24 October 2025
Procedural Posture: Statutory Review (planning and Compulsory Purchase Act 2004, S.113) / Judgment After Substantive Hearing
Outcome: Claim dismissed
Legal Topics: Green Belt Policy, Development Plan Documents, Exceptional Circumstances Test, Judicial Review of Planning Decisions, Interpretation of National Planning Policy Framework (nppf), Statutory Review Procedure

Planning and Environment Law Administrative Law Local Government Law Green Belt Policy Development Plan Documents Exceptional Circumstances Test Judicial Review of Planning Decisions Interpretation of National Planning Policy Framework (nppf) +1 more

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Parties

SAVE GREATER MANCHESTER GREEN BELT LIMITED

Claimant

SECRETARY OF STATE FOR HOUSING, COMMUNITIES AND LOCAL GOVERNMENT

First Defendant

GREATER MANCHESTER COMBINED AUTHORITY

Second Defendant

BOLTON COUNCIL

Third Defendant

BURY COUNCIL

Fourth Defendant

MANCHESTER CITY COUNCIL

Fifth Defendant

OLDHAM COUNCIL

Sixth Defendant

SALFORD CITY COUNCIL

Seventh Defendant

ROCHDALE BOROUGH COUNCIL

Eighth Defendant

TAMESIDE METROPOLITAN BOROUGH COUNCIL

Ninth Defendant

TRAFFORD COUNCIL

Tenth Defendant

WIGAN COUNCIL

Eleventh Defendant

WAIN ESTATES (CARRINGTON) LIMITED

First Interested Party

WAIN ESTATES (LAND) LIMITED

Second Interested Party

PEEL L&P INVESTMENTS (NORTH) LIMITED

Third Interested Party

RLUKREF NOMINEES (UK) ONE LIMITED

Fourth Interested Party

RLUKREF NOMINEES (UK) TWO LIMITED

Fifth Interested Party

Procedural Posture

Statutory Review (planning and Compulsory Purchase Act 2004, S.113) / Judgment After Substantive Hearing

Legal Issues

1 Whether the Inspectors erred in law in their approach to what was capable of constituting exceptional circumstances to justify adding sites to the Green Belt
2 If there was an error, whether it was potentially material to the decision
3 What remedy would be appropriate if an error was found

Ratio Decidendi

Court Disposition

Claim dismissed