Southern Housing v Emmanuel [2025] EWCC 58 (27 October 2025)

Southern Housing v Emmanuel [2025] EWCC 58 (27 October 2025)

The County Court has no power to authorise a landlord to force entry into a tenant's home to enforce an access injunction; only Parliament can confer such power, and the Civil Procedure Rules cannot override substantive rights of exclusive possession and privacy.

Citation
[2025] EWCC 58
Parties
Claimant: Southern Housing; Defendant: Mr James Emmanuel
Jurisdiction
England and Wales
Judgment Date
27 October 2025
Procedural Posture
Injunction Application (part 8 Proceedings) / Post Hearing Judgment on Application to Vary Injunction
Outcome
Application dismissed
Legal Topics
Access Injunctions, Forced Entry, Exclusive Possession, Enforcement of Court Orders, Gas Safety Checks

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Parties

Southern Housing

Claimant

Mr James Emmanuel

Defendant

Procedural Posture

Injunction Application (part 8 Proceedings) / Post Hearing Judgment on Application to Vary Injunction

  1. 1 Does the County Court have power to authorise a landlord to force entry into a tenant's home to enforce an access injunction?
  2. 2 Can Civil Procedure Rules (CPR) be used to override a tenant's exclusive possession and privacy rights absent express statutory authority?

Ratio Decidendi

The County Court has no power to authorise a landlord to force entry into a tenant's home to enforce an access injunction; only Parliament can confer such power, and the Civil Procedure Rules cannot override substantive rights of exclusive possession and privacy.

Court Disposition

Application dismissed

Orders

  • Claimant's application to vary injunction to permit forced entry is dismissed