Save Greater Manchester Green Belt Ltd v Secretary of State for Housing, Communities and Local Government & Ors [2025] EWHC 2742 (Admin) (24 October 2025)

Save Greater Manchester Green Belt Ltd v Secretary of State for Housing, Communities and Local Government & Ors [2025] EWHC 2742 (Admin) (24 October 2025)

The Inspectors did not err in law in their approach to the 'exceptional circumstances' test for Green Belt additions. They lawfully treated fundamental change and boundary anomaly as relevant but not exclusive criteria, exercised their planning judgment, and did not fetter their discretion or exclude other relevant considerations. The claim is dismissed.

Citation
[2025] EWHC 2742 (Admin)
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 Under Section 113 of the Planning and Compulsory Purchase Act 2004 / Final Judgment After Substantive Hearing
Outcome
Claim dismissed
Legal Topics
Statutory Review of Development Plan Documents, Green Belt Policy, Exceptional Circumstances Test, Interpretation of National Planning Policy Framework, Judicial Review Principles in Planning Context
Administrative Law Planning Law Local Government Law Statutory Review of Development Plan Documents Green Belt Policy Exceptional Circumstances Test Interpretation of National Planning Policy Framework Judicial Review Principles in Planning Context

Case Brief

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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 Under Section 113 of the Planning and Compulsory Purchase Act 2004 / Final Judgment After Substantive Hearing

Legal Issues

  1. 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. 2 If so, whether this error was potentially material to the decision reached
  3. 3 What remedy is appropriate if an error is found

Ratio Decidendi

The Inspectors did not err in law in their approach to the 'exceptional circumstances' test for Green Belt additions. They lawfully treated fundamental change and boundary anomaly as relevant but not exclusive criteria, exercised their planning judgment, and did not fetter their discretion or exclude other relevant considerations. The claim is dismissed.

Court Disposition

Claim dismissed

Orders

  • The claim for statutory review is dismissed.
  • No order for quashing or remittal of the Plan.