BDW Trading Ltd & Anor v South Anglia Housing Ltd

BDW Trading Ltd & Anor v South Anglia Housing Ltd

The consultation requirements of section 20 of the Landlord and Tenant Act 1985 do not apply to long term agreements entered into before any tenants exist, as the statutory language does not extend to future or prospective landlords and there is no basis for stretching its meaning.

Parties
Claimant: BDW Trading Limited; Claimant: Comet Square Phase 2 Block Management Co Ltd; Defendant: South Anglia Housing Ltd
Jurisdiction
England and Wales
Judgment Date
15 July 2013
Procedural Posture
Civil / Judgment After Hearing
Outcome
Claim allowed
Legal Topics
Service Charges, Consultation Requirements, Qualifying Long Term Agreements, Statutory Interpretation

Case Brief

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Parties

BDW Trading Limited

Claimant

Comet Square Phase 2 Block Management Co Ltd

Claimant

South Anglia Housing Ltd

Defendant

Procedural Posture

Civil / Judgment After Hearing

  1. 1 Does section 20 of the Landlord and Tenant Act 1985 apply to long term agreements entered into before any tenants exist?
  2. 2 Is the owner required to consult non-existent tenants or seek dispensation from the LVT for such agreements?

Ratio Decidendi

The consultation requirements of section 20 of the Landlord and Tenant Act 1985 do not apply to long term agreements entered into before any tenants exist, as the statutory language does not extend to future or prospective landlords and there is no basis for stretching its meaning.

Court Disposition

Claim allowed

Orders

  • Declaration that the consultation requirements of the Act do not apply to the agreement in question