Landy Palmer & Ors v The Council of the City of Plymouth & Anor [2026] EWHC 1262 (Ch)

[2026] EWHC 1262 (Ch)Case No PT-2025-BRS-000093IN THE HIGH COURT OF JUSTICEVenue BUSINESS AND PROPERTY COURTS IN BRISTOLPROPERTY, TRUSTS AND PROBATE LIST (ChD)Venue Bristol Civil Justice Centre, 2 Redcliff Street, Bristol, BS1 6GRDate 28 May 2026HHJ PAUL MATTHEWS(sitting as a Judge of the High Court)
LANDY PALMERClaimantsand 88 OTHERSClaimantTHE COUNCIL OF THE CITY OF PLYMOUTHDefendantsTHE CORNWALL COUNCILDefendant
Tom Weekes KC (instructed by Lee Bolton Monier-Williams LLP) for ClaimantsMichael Paget (instructed by Plymouth City Council Legal Services) for DefendantsHearing Hearing date: 28 January 2026
This judgment was handed down remotely at 10.15 am on 28 May 2026 by circulation to the parties or their representatives by e-mail and by release to the National Archives.HHJ Paul Matthews :

Introduction

[1]This is my judgment on the trial of a claim made by claim form under CPR Part 8 issued on 12 August 2025. The claim form is accompanied by a document called “Details of Claim”. This was amended on 30 September 2025, and is itself accompanied by a lengthy annex of relevant documents. The claim is for declarations that the defendant landlords are not entitled to the payment of premiums on the assignment of leases which they have granted to the claimant tenants. The claim is supported by the witness statement of the first claimant, Landy Palmer, dated 7 August 2025, together with one exhibit. The defendants did not file any evidence in answer, but there is an agreed bundle of documents before the court, and there are no serious disagreements between the parties on the facts.[2]The issues which I have to decide relate to the construction of certain leases, and the effect of certain legislation upon them. The parties were agreed that a claim under CPR Part 8 was appropriate for this purpose. The matter was argued before me on 28 January 2026. On 15 April 2026, during the course of preparation of this judgment, I asked the parties for further submissions on certain points. These were supplied in written form, on 20 April and 6 May respectively, and I have considered them. I am sorry for the delay in handing down this judgment, caused by pressure of other, unfortunately more urgent, work.[3]The claimants are all tenants under 21-year leases granted in 2022 by the defendants in identical form, each lease relating to a plot of land sufficient for the erection of a large hut or a chalet. The plots are on a stretch of cliffs at Whitsand Bay, historically within the Mount Edgcumbe estate on the Rame Peninsula in Cornwall (south of Torpoint, and close to Plymouth in Devon). The practice of building huts and chalets here for recreational use apparently dates back to the 1930s. The freehold of this land was sold to the defendants in 1971, who have since then let plots from time to time for the erection of such huts or chalets, to be used, in effect, as holiday homes. There are currently 71 plots, and the 89 claimants are the lessees of 56 of them.[4]I set out below(1) a map of the area (bounded by a red line) and(2) an aerial photograph of a part of it to give the reader some idea of the terrain. The chalets face south-west across the English Channel.[5]The issue which is to be resolved by this claim concerns payments by leaseholders for landlord’s consent to assign their leases. In legal terms, it is whether the defendant landlords are entitled, pursuant to the terms of the alienation covenants, but in the light of statutory restrictions on such covenants, to make grants of consent for assignments conditional(i) on a first assignment, on the payment of 75% of the higher of the sale price and the market value of the lease; and(ii) on subsequent assignments, on the payment of 20% of the higher of the sale price and the market value. The defendants say Yes, and the claimants say No.[6]Since not all the tenants are parties to this claim, there is a question as to how far the non-parties can be bound by my judgment. I make clear here that I was not asked to deal with this issue, and say nothing more about it. Background[7]The present leases of the plots of land are not the first such leases to be granted. In the first years of this century, earlier leases, also of 21 years, were granted in relation to those plots. In this judgment these leases are referred to as “Old Leases”, to distinguish them from those granted in 2022, which are referred to as “New Leases”. At the time of the earlier leases, most if not all of these plots of land already had a large hut or chalet erected upon them. The recitals to the leases (both “Old” and “New”) reflected this state of affairs. Thus, the first recital to the New Leases was in this form: “THERE is now standing upon the plot of land situate at Treninnow and Wiggle Cliffs in the Parish of Maker-with-Rame in the County of Cornwall forming part of Mount Edgcumbe Country Park (freehold title no. CL307759 at the Land Registry) and delineated on the plans annexed hereto and thereon shown edged red and numbered [ ] a structure comprising a recreational chalet or hut (which chalet or hut (together with any ancillary outbuildings, erections or structures) is the property of the Tenant) now called Chalet No [ ] Treninnow & Wiggle Cliffs”.[8]On 7 September 2023, the claimants’ solicitors sent a letter before claim to the defendants. This set out the claim in some detail. In that letter, the solicitors said this:
“Preliminary Question: The ownership of the Chalets? The Old 21-Year Leases: (1) stated (in a recital) that situated on each Plot was ‘a recreational chattel Sic. The lease recital actually said “chalet”. or hut … now belonging to and removable by the Lessee’; and (2) required the tenant to remove the chalet at the end of the Lease.”
[9]The solicitors then set out the terms of the first recital to the new standard lease, and continued:
“It is our view that, notwithstanding the recital set out above, the chalets form part and parcel of the Plots and are accordingly owned by the Councils as freeholders. The chalets are clearly attached to the land on which they are situated.”
[10]The response of the defendants’ solicitors, dated 20 October 2023, included the following paragraph:
“Under the heading – Preliminary Question – the case-law is set out including a case involving a chalet (albeit one where there was no restriction on year-round occupation). The Councils do not dispute that case-law and accept that the chalets are not chattels. It will be a question of fact in each case whether the chalets are removable and so remain tenant’s fixtures; it is likely that many chalets could not be removed without being destroyed.”
[11]It is clear from the language used that the defendants in that letter accepted “that the chalets are not chattels”. They were possibly “tenant’s fixtures”, although this was not clear, but at all events they were to be treated as part of the land. A lease of the land would therefore include a lease of the chalet standing upon it. However, the defendants’ skeleton argument, prepared immediately before the hearing, appeared to proceed on the basis that the leases were only of the land and not also of the chalets. But the defendants had not filed any evidence dealing with this question. The claimants’ evidence filed, as well as their skeleton argument, had not addressed this question either.[12]Accordingly, during the hearing, I asked the defendant’s counsel, Mr Paget, for clarification on this point. After considering the matter and taking instructions, he informed me that the defendants wished to proceed on the basis that the chalets either were not, or at least might not be, fixtures, and therefore not subject to the demises. On behalf of the claimants, Mr Weekes KC opposed any change of position on the part of the defendants. After hearing argument from both sides, I gave a short extempore judgment, in which I decided that the interests of justice required that I refuse permission to the defendants to change their position as stated in their letter of 20 October 2023. The case had been prepared on that basis, and there was no evidence sufficient to deal with the point before the court, which would therefore necessitate the abandonment of the current trial, the filing of further evidence, and the relisting of the trial. Accordingly, I have proceeded on the basis that the chalets were fixtures, and subject to the Leases.[13]The chalets differ significantly from each other in size and other amenities. According to the claimants’ evidence (which I accept), a voluntary questionnaire to tenants elicited 67 (out of 81 possible) replies. Of the 67 completed questionnaires, 6% stated that the chalet had no bedroom, 27% stated that it had one bedroom, 54% stated that it had two bedrooms, 11% stated that it had three bedrooms, and 1% that it had four bedrooms (for present purposes, I do not distinguish between single and double bedrooms). Again of the completed questionnaires, 12% of the replies stated that the chalet had been rebuilt or substantially extended in the last decade, 24% that it this had happened within the previous decade, and 64% that this had not happened in the last two decades. All the replies indicated that their chalet had mains water, and that 97% had a WC (with soakaway or septic tank), of which 75% were inside the chalet, and that 94% had a shower. As for power, 69% of replies indicated that the chalet had solar panels, whilst 16% indicated that it had mains electricity (there were some that had both), and 11% stated that it had other means of electricity generation. The terms of the leases

The Old Leases

[14]The Old Leases contained the following provisions, amongst others:
“3. The Lessee hereby covenants with the Lessor as follows:- [ … ] (vii) Not to use the chalet site or any building or structure thereon nor permit or suffer the chalet to be used (either by the Lessee or any other person whomsoever) for any purpose other than for recreational purposes for eleven months of the year for use primarily by the Lessee or the Lessee’s families and the chalet shall not be used for the period from the 10th January to 9th February in each year (or such other one month period as may be specified by the Lessors). [ … ] (ix) (a) Not to assign the whole benefit of this Lease without the prior written consent of the Lessors such consent not to be unreasonably withheld… (b) Not to share the use of or part with the possession of the chalet site or any part thereof or assign the benefit of part only of this Lease or grant any licence to occupy reside or stay at or use or permit or suffer any person other than the Lessee or the Lessee’s families to occupy reside or stay at or use the chalet site or any building erection or structure thereon or any part thereof respectively EXCEPT that … the Lessee shall be entitled to grant occasional licences for occasional use of the chalet site or other building erection or structure thereon or any part thereof respectively by other respectable persons for occasional recreational purposes. [ … ] (xii) Not to carry on or permit or suffer to be carried on either in relation to or on or in the chalet site or any building erection or structure from time to time thereon or any part thereof respectively any trade or business and in particular but without prejudice to the generality of this paragraph not to carry on or permit or suffer to be carried on the trade or business of letting or licensing the occupation or use of the chalet site or any building erection or structure from time to time thereon PROVIDED that without prejudice to any other covenant condition agreement or provision in this Lease contained nothing in this sub-clause contained or implied shall be deemed to prevent the granting of occupational licences by the Lessee as permitted in sub-clause (ix)(b) hereof.”

The negotiations for the New Leases

[15]Before the Old Leases expired, the defendants engaged surveyors Jones Lang LaSalle to report on the options available to them on the expiry of those leases. That report recommended renewing the leases based on a fair market rent, and relaxing the restrictions on subletting for holiday use. The defendants accepted this recommendation. A report to the “Joint Committee” of the two defendant authorities in November 2020 stated:
“The chalet site tenants now need to be informed of the terms of the new ground leases that will come into effect from September 2021 onwards and this action will commence the lease renewal process. A draft communication plan is being drafted that will:  Explain the rationale behind the lease increase  Inform chalet leaseholders of what they need to do and when  Be transparent about the increase and the wider benefits to Rame and Mount Edgcumbe It is being built around the following proposed messages:  It will help secure the long-term future of Mount Edgcumbe by reducing its reliance on subsidies from Cornwall and Plymouth residents  The proposed increase reflects the market value that the local authorities are under an obligation to achieve  Whilst this is a big increase the conditions of the lease are being enhanced to enable holiday lettings  More than 60% of leaseholders live outside Plymouth and Cornwall and use the chalets as second homes – given the enormous pressures being faced by local authorities it feels inappropriate that local council tax payers should be subsidising a cheap ground rent”
. A draft communication plan is being drafted that will:  Explain the rationale behind the lease increase  Inform chalet leaseholders of what they need to do and when  Be transparent about the increase and the wider benefits to Rame and Mount Edgcumbe

It is being built around the following proposed messages:

[16]In February 2021, the defendant landlords offered the lessees new leases with terms of 30 years from 29 September 2021 at a rent of £4000 per year, on terms not prohibiting assignment. It appears that the defendants were concerned that there was a strong demand driven by the coronavirus pandemic which had a significant impact on the value of such leases. In July 2021 the claimants by their agent surveyor rejected those terms. But the defendants resisted, and considered that they nevertheless were in a strong position.[17]According to their evidence they were “aware that, in recent years (and prior to the pandemic), chalet plots have changed hands for significant sums. In their view, much of this value is attributable to the unique location of the plots, and should rightfully accrue to the benefit of the landlord rather than the tenant. In addition, of course, in the last 18 months there has been a huge increase in the popularity of the Comish coast for holidays and second homes, and they consider that has increased the market value of plots, and that this uplift is likely to be permanent.”[18]In response to the tenants’ rejection of the new terms offered, the defendants wrote to the tenants’ representative (amongst other things):
“Self-generated evidence from the chalet plots themselves of this increase in market values is strongly illustrated by 26 Trenninow which has been on the market with a guide price of £250,000 and is now reported as sold Subject to Contract on the agent's website. This sale is based on the renewal terms the Councils issued in February … It is evident that due to the ongoing impact of the pandemic on the market, significant premiums could be immediately secured by tenants if the Councils were to proceed with the February renewal terms. On account of the statutory obligation for Councils to obtain best consideration under the 1972 Local Government Act, the Councils accordingly now need to undertake a further review of appropriate long lease terms to offer.”
[19]Accordingly, the defendants took further advice. They thought that they had at least three options. The first was to require a premium on the grant of the new leases. The second was to restrict the power to assign the leases. The third was to require a clawback of the price obtained (or the then market value, if higher) on assignment of the lease in the future.[20]The Committee of the Tenants’ Association reported the landlords’ position to its members in part as follows:
“We must remind you that, as a matter of law, Plymouth City Council acting on behalf of the Mount Edgcumbe Estate is legally obliged to secure the best financial return that can reasonably be obtained. The landlords are aware that, in recent years (and prior to the pandemic), chalet plots have changed hands for significant sums. In their view, much of this value is attributable to the unique location of the plots, and should rightfully accrue to the benefit of the landlord rather than the tenant. In addition, of course, in the last 18 months there has been a huge increase in the popularity of the Comish coast for holidays and second homes, and they consider that has increased the market value of plots, and that this uplift is likely to be permanent. The council is currently considering a range of possible provisions which would enable the landlord to benefit from the increase in values. These possibilities include: - charging a premium for the granting of a lease - restricting the power to assign following the granting of a lease - subjecting the power to assign to a ‘claw-back’ provision, entitling the landlords to a proportion of the proceeds of assignment. Please note that these are ideas currently being discussed and they may or may not be included in the draft lease when finalised. We must keep an open mind about how widely such provisions may vary from the terms we have come to expect from previous lease renewals.”
[21]A report to the Joint Committee in November 2021 referred to professional advice from Jones Lang LaSalle “in respect of the appropriate market lease terms to offer, with particular regard to the Councils' statutory duty to obtain best value”, and recommended the third possibility. So there would be no premium on grant, and assignments would be permitted, as would subletting, but there would be a ‘claw-back’ provision, entitling the landlords to a proportion of the proceeds of assignment. The report went on to say that:
“The new terms will protect the Councils' position at assignment by ensuring that the Councils receive an appropriate share of any assignment premium secured by the tenant or market value if higher.”
[22]I have no basis for rejecting any of this evidence, and indeed I accept it. In February 2022, the defendants offered the lessees new leases of 21 years from September 2022 at a rent of £5000 per annum, subject to review. In March 2022, the defendants agreed to enter into the new leases. The claimants, professionally advised, did so too. The claimants also agreed to exclude sections 24-28 of the Landlord and Tenant Act 1954.

The New Leases

[23]The 21-year leases of 2022 contained the following definitions, amongst others. Recital (1) of the New Leases reads:
“THERE is now standing upon the plot of land situate at Treninnow and Wiggle Cliffs in the Parish of Maker-with-Rame in the County of Cornwall forming part of Mount Edgcumbe Country Park (freehold title no. CL307759 at the Land Registry) and delineated on the plans annexed hereto and thereon shown edged red and numbered [ ] a structure comprising a recreational chalet or hut (which chalet or hut (together with any ancillary outbuildings, erections or structures) is the property of the Tenant) now called Chalet [ ], Treninnow & Wiggle Cliffs.”
In Recital (2), it is stated that “the said recreational chalet or hut [is] hereinafter referred to as ‘the Chalet’ … ”[24]In clause 1 of the New Leases, the operative demise is set out, including the definition of the phrase “the Chalet Site” as follows: “the Landlord hereby demises unto the Tenant the plot of land situate at Treninnow and Wiggle Cliffs in the Parish of Maker-with-Rame in the County of Cornwall forming part of Mount Edgcumbe Country Park (freehold title no. CL307759 at the Land Registry} and delineated on the plans annexed hereto and thereon shown edged red and numbered [ ] (hereinafter called ‘the Chalet Site’)”.[25]The New Leases contain the following operative tenant’s covenants, amongst others: “3.3(a) Not to erect any building erection or structure … on the Chalet Site without the prior written consent of the Landlord (such consent not to be unreasonably withheld or delayed) … [ … ] 3.7. Not to use the Chalet Site or any building, erection or structure thereon nor permit or suffer the Chalet to be used (either by the Tenant or any other person whomsoever) for any purpose other than for recreational purposes for eleven months each year, and the Chalet shall not be used or occupied for any purpose for the period from the 10th January to 9th February in each year (or such other one month period as may be specified by the Landlord), and the Chalet shall not be used as the only or main residence of any person or otherwise used as a dwelling. [ … ] 3.9.2. Not to assign the whole of this Lease without prior written consent from the Landlord, such consent not to be unreasonably withheld subject to the provisions of sub-clauses 3.9.4 and 3.9.5 below. [ … ] 3.9.4 The Landlord and Tenant agree that for the purposes of section 19(1A) of the Landlord and Tenant Act 1927 (and notwithstanding anything in Section 144 of the Law of Property Act 1925) the Landlord may give its consent to an assignment subject to the following conditions:(a) a condition that on the first assignment of this Lease…the Tenant pays to the Landlord a sum of money equal to seventy-five per cent (75%) of the higher of: (i) the sale price or other monetary consideration payable for the proposed assignment (as certified by the Tenant’s Solicitor); or (ii) the then current fair open market value (as agreed by the Landlord and the Tenant in writing or as conclusively determined in accordance with the Fifth Schedule to this Lease) of the leasehold interest under this Lease.(b) a condition that on any assignment of this Lease … subsequent to an assignment to which sub-paragraph (a) applies, the Tenant pays to the Landlord a sum of money equal to twenty per cent (20%) of the higher of: (i) the sale price or other monetary consideration payable for the proposed assignment (as certified by the Tenant’s Solicitor); or (ii) the then current fair open market value (as agreed by the Landlord and the Tenant in writing or as conclusively determined in accordance with the Fifth Schedule to this Lease) of the leasehold interest under this Lease. [ … ] 3.9.7. Not to underlet, share the use of or part with the possession of the Chalet Site or any part thereof save that the Tenant shall be entitled (but only during the months of March, April, May, June and July in each year) to grant short term holiday lettings (not exceeding three weeks for any individual letting) of the Chalet to a maximum of two adults (and no children) at any one time … [ … ] 3.11. Not to carry on, or permit or suffer to be carried on, either in relation to or on or in the Chalet Site or any building erection or structure from time to time thereon or any part thereof respectively, any trade or business PROVIDED THAT the granting of short term holiday lettings of the Chalet by the Tenant in accordance with sub-clause 3.9.7 hereof shall not constitute a breach of this clause.” (a) a condition that on the first assignment of this Lease…the Tenant pays to the Landlord a sum of money equal to seventy-five per cent (75%) of the higher of: (i) the sale price or other monetary consideration payable for the proposed assignment (as certified by the Tenant’s Solicitor); or (ii) the then current fair open market value (as agreed by the Landlord and the Tenant in writing or as conclusively determined in accordance with the Fifth Schedule to this Lease) of the leasehold interest under this Lease. (b) a condition that on any assignment of this Lease … subsequent to an assignment to which sub-paragraph (a) applies, the Tenant pays to the Landlord a sum of money equal to twenty per cent (20%) of the higher of: (i) the sale price or other monetary consideration payable for the proposed assignment (as certified by the Tenant’s Solicitor); or (ii) the then current fair open market value (as agreed by the Landlord and the Tenant in writing or as conclusively determined in accordance with the Fifth Schedule to this Lease) of the leasehold interest under this Lease. Declarations sought[26]In the Details of Claim attached to the claim form, the remedy claimed by the claimants is as follows:
“35. The Claimants seek declarations that: a. Clause 3.9.4 of the Leases is void. b. The Defendants are not entitled to make grants of consent for assignments of the Leases subject to a condition requiring the payment of a premium (whether the premiums stipulated in clause 3.9.4 or any other premiums).” a. Clause 3.9.4 of the Leases is void. b. The Defendants are not entitled to make grants of consent for assignments of the Leases subject to a condition requiring the payment of a premium (whether the premiums stipulated in clause 3.9.4 or any other premiums).”
The law

Hypothetical questions

[27]I begin my reminding myself that the court does not generally decide hypothetical questions. A number of cases of high authority support this proposition, including Glasgow Navigation Co v Iron Ore Co [1910] AC 293, HL, Sun Life Assurance Company of Canada v Jervis [1944] AC 111, HL, Ainsbury v Millington [1987] 1 WLR 379, HL, R v Home Secretary, ex p Salem ]1999] 1 AC 450, HL, and Rolls Royce plc v Unite the Union [2010] 1 WLR 318, CA.[28]More recently, Cockerill J (as she then was) summarised the current approach to hypothetical questions in BNP Paribas SA v Trattamento Rifiuti Metropolitana SpA [2020] EWHC 2436 (Comm). In that case she said:
“78. … (v) This emphasis on doing justice in the particular case is reflected in the limitations which are generally applied. Thus: a) The court will not entertain purely hypothetical questions. It will not pronounce upon legal situations which may arise, but generally upon those which have arisen: Zamir & Woolf at 4-036 & Regina (Al Rawi) v Sec State Foreign & Commonwealth Affairs [2008] QB 289 at 344. b) There must in general, be a real and present dispute between the parties before the court as to the existence or extent of a legal right between them: Rolls Royce [v Unite the Union [2010] 1 WLR 318]at [120]. c) If the issue in dispute is not based on concrete facts the issue can still be treated as hypothetical. This can be characterised as ‘the missing element which makes a case hypothetical’: see Zamir & Woolf at 4-59.”
[29]More recently still, in Hillingdon LBC v AP [2026] EWCA Civ 216, Cobb LJ (with whom Phillips and Stuart-Smith LJJ agreed) said:
“20. It is a long-established principle that a court, whether first instance or appellate, will only make determinations on matters which are truly in dispute between the parties; Lord Bridge commented in Ainsbury v Millington [1987] 1 WLR 379 at 381 that courts do not ‘pronounce on abstract questions of law where there is no dispute to be resolved’. An exception is recognised for arguments on points of law (especially in public law cases) which, although ‘academic’ or "hypothetical’, are points of general public interest. Even if it were such a case, the court's discretion to hear such an appeal would always be exercised with caution, and the jurisdiction to proceed is a narrow one (R v Secretary of State for the Home Department Ex p. Salem [1999] 2 WLR 483, HL).”

Covenants restricting alienation

[30]I turn now to leasehold covenants concerned with the alienation of leases. These are of several distinct kinds, to which landlord and tenant lawyers have assigned generally accepted names. An “absolute” covenant is one which simply forbids alienation without more. It is of course open to the landlord to waive the benefit, or license the breach, of such a covenant if it thinks fit. A “qualified” covenant is one which expresses this option, by providing that alienation is forbidden without the landlord’s consent. Conceptually, as it seems to me, there is no difference between the two categories. Instead, it is a matter of form rather than substance: cfBocardo SA v S & M Hotels Ltd [1980] 1 WLR 17, 22D-E, per Megaw LJ. Nevertheless, this difference in form is the basis for different treatment in substance by statute. Thirdly, there is the “fully-qualified” covenant, in which alienation is forbidden without the landlord’s consent, but it is expressly provided that such consent is not to be unreasonably withheld. If consent is then unreasonably withheld, the tenant is free to alienate: Treloar v Bigge (1874) LR 9 Ex 15, approved in Houlder Bros & Co Ltd v Gibbs [1925] 1 Ch 575, CA.[31]The purpose of a fully-qualified covenant was explained by Balcombe LJ, with whom Fox and Mustill LJJ agreed, in International Drilling Fluids Ltd v Louisville Investments (Uxbridge) Ltd [1986] 1 Ch 516, after discussing the caselaw going back to 1896, He said (at 519-520):
“(1) The purpose of a covenant against assignment without the consent of the landlord, such consent not to be unreasonably withheld, is to protect the lessor from having his premises used or occupied in an undesirable way, or by an undesirable tenant or assignee … (2) As a corollary to the first proposition, a landlord is not entitled to refuse his consent to an assignment on grounds which have nothing whatever to do with the relationship of landlord and tenant in regard to the subject matter of the lease … ”
[32]The relevant legislation is the following. The Law of Property Act 1925, section 144 (re-enacting section 3 of the Conveyancing and Law of Property Act 1892) provides as follows:
“In all leases containing a covenant, condition, or agreement against assigning, underletting, or parting with possession, or disposing of the land without licence or consent, such covenant, condition, or agreement shall, unless the lease contains an express provision to the contrary, be deemed to be subject to a proviso to the effect that no fine or sum of money in the nature of a fine shall be payable for or in respect of such licence or consent; but this proviso does not preclude the right to require the payment of a reasonable sum in respect of any legal or other expense incurred in relation to such licence or consent.”
[33]In West v Gwynne [1911] 2 Ch 1, CA, Sir Herbert Cozens-Hardy MR referred to section 3, and said (at 11):
“ … the Legislature appears to have regarded the exaction of a fine as the price of consent to an assignment as so unreasonable that it ought not to be deemed to have been part of the bargain unless expressly mentioned in the lease itself. This is a question of general policy equally applicable to all leases.”
[34]I was also referred to the case of Waite v Jennings [1906] 2 KB 11, CA. This was a decision under section 3 of the Conveyancing and Law of Property Act 1892, the predecessor of section 144 of the 1925 Act. A lease contained a condition against assigning without licence, which was not to be refused unreasonably, but there was no provision as to payment of a fine in respect of such a licence. The leaseholder sought a licence to assign to the defendant in this action from the plaintiff landlord. The landlord made it a condition of granting the licence that the defendant should covenant to pay the rent and perform the covenants of the lease during the residue of the term. The licence to assign was made by deed to which the defendant was a party, and in which he entered into the stipulated covenant. The defendant subsequently assigned the lease, again with licence. The new tenant did not pay the rent, and the landlord sued the defendant on his covenant. The defendant argued that the covenant constituted a fine within section 3 of the 1892 Act, and that it was accordingly void.[35]The majority of the Court of Appeal (Vaughan Williams and Stirling LJJ) considered that the covenant was not in the nature of a fine within section 3. However, the whole court (including Fletcher Moulton LJ) held that, whether or not the covenant was in the nature of a fine, section 3 did not make the payment of a fine unlawful. Vaughan Williams LJ said (at 16):
“The effect of that section is not to make the payment of a fine an illegal thing, but only to read into the lease, as between the parties to it, a provision that no fine shall be payable for a licence to assign. The defendant, as a proposed assignee, is not a party to the lease, and under those circumstances it seems to be impossible for the defendant to get out of the provisions of s. 3 of the Act of 1892 a defence to this action.”
And Stirling LJ said (at 16):
“I am of the same opinion. Sect. 3 of the Conveyancing Act, 1892, does not prohibit the taking of a fine on the granting of a licence to assign.”
[36]Fletcher Moulton LJ put it this way (at 18-19):
“The Legislature does not make the exaction of a fine a malum prohibitum, but only reads into the lease a covenant in favour of the leaseholder that no fine shall be exacted, and he alone can take advantage of it. This is perfectly just. The price paid for a licence to assign must in the ordinary course come out of the pocket of the assignor, whether it is paid by him or by the assignee, for, taking the present case as an instance, the defendant who was going to purchase the lease must be assumed to have taken into consideration the obligation under which he came by reason of the covenant in determining what he would give for the lease. It therefore lessened the price which the assignor obtained for the lease and to that extent injured him, but it did not injure anyone else.”
[37]So, because the defendant in that case was himself an assignee, and therefore was not a party to the lease, he could not take advantage of the provision implied by section 3 that no fine should be payable for a licence to assign. In his favour, there was no such provision. Accordingly, even if the covenant he gave had amounted to a fine, he could not rely on section 3 to make it unenforceable.[38]The principal sub-issue in this case is whether, and if so how, the effect of this provision (now in section 144) was altered by the enactment of the Landlord and Tenant Act 1927, section 19, which itself was amended in 1995. The original section 19 was a new enactment in 1927, although an attempt had been made to introduce a similar provision in 1891, in what became section 3 of the Conveyancing and Law of Property Act 1892: see Commons Hansard, 4 March 1891, vol 351, col 141. That early attempt appears to have failed because of opposition by professional landlords (including the then Prime Minister, the Marquess of Salisbury: see Lords Hansard, 4 August 1891, vol 356, cols 1225-1227). But really it does not matter why. The point is that, although it was put forward as part of the bill, ultimately it formed no part of the 1892 Act, or subsequently of the Law of Property Act 1925.[39]As passed in 1927, and then amended in 1995, section 19 relevantly provides as follows: “(1) In all leases whether made before or after the commencement of this Act containing a covenant condition or agreement against assigning, underletting, charging or parting with the possession of demised premises or any part thereof without licence or consent, such covenant condition or agreement shall, notwithstanding any express provision to the contrary, be deemed to be subject –(a) to a proviso to the effect that such licence or consent is not to be unreasonably withheld, but this proviso does not preclude the right of the landlord to require payment of a reasonable sum in respect of any legal or other expenses incurred in connection with such licence or consent; and [ … ] [(1A) Where the landlord and the tenant under a qualifying lease have entered into an agreement specifying for the purposes of this subsection— (a) any circumstances in which the landlord may withhold his licence or consent to an assignment of the demised premises or any part of them, or(b) any conditions subject to which any such licence or consent may be granted, then the landlord— (i) shall not be regarded as unreasonably withholding his licence or consent to any such assignment if he withholds it on the ground (and it is the case) that any such circumstances exist, and (ii) if he gives any such licence or consent subject to any such conditions, shall not be regarded as giving it subject to unreasonable conditions … [ … ] (1E) In subsection (1A) and (1D) of this section … ‘qualifying lease’ means any lease which is a new tenancy for the purposes of section 1 of the Landlord and Tenant (Covenants) Act 1995 other than a residential lease, namely a lease by which a building or part of a building is let wholly or mainly as a single private residence…]” [ … ] (4) This section shall not apply to leases of agricultural holdings within the meaning of the [Agricultural Holdings Act 1986] [which are leases in relation to which that Act applies, or to farm business tenancies within the meaning of the Agricultural Tenancies Act 1995], and paragraph (b) of subsection (1), subsection (2) and subsection (3) of this section shall not apply to mining leases.” (a) to a proviso to the effect that such licence or consent is not to be unreasonably withheld, but this proviso does not preclude the right of the landlord to require payment of a reasonable sum in respect of any legal or other expenses incurred in connection with such licence or consent; and (a) any circumstances in which the landlord may withhold his licence or consent to an assignment of the demised premises or any part of them, or (b) any conditions subject to which any such licence or consent may be granted, then the landlord— (i) shall not be regarded as unreasonably withholding his licence or consent to any such assignment if he withholds it on the ground (and it is the case) that any such circumstances exist, and (ii) if he gives any such licence or consent subject to any such conditions, shall not be regarded as giving it subject to unreasonable conditions …[40]Subsection (1) has never been amended, and remains in its original form. Subsections (1A) to (1E) are new, and were inserted by the Landlord and Tenant (Covenants) Act 1995, section 22. Subsection (4) is affected only by consequential amendments.[41]The effect of the unamended section 19(1) was, with limited exceptions, to convert all qualified covenants in leases to which it applied to fully-qualified covenants. The main exceptions were for agricultural tenancies and (now) farm business tenancies, which have special features. Moreover, this section (unlike section 3 of the 1892 Act and then section 144 of the 1925 Act) did not provide the parties with any ability to contract out of the conversion. This inability originally extended to attempts to stipulate, in the lease itself, circumstances in which a refusal of consent would be reasonable (Smith v Richards [1951] 1 All ER 346, 349, Roxburgh J), though the law on this point has in effect been reversed since the introduction in 1995 of section 19(1E), discussed shortly.[42]I do not think that I need to decide whether a conditional consent is to be treated as a refusal. I note in passing however that it was the view taken by the legislature in the Landlord and Tenant Act 1988, section 1(4), set out below. Similarly, I am not aware of any authority which deals with the question of which party has the burden under section 19 of showing that a refusal is consent is reasonable or unreasonable. At common law, “[o]ne of the most basic rules of litigation is that he who asserts must prove”: Sadovska v Home Secretary [2017] 1 WLR 2926, [28] per Lady Hale (with whom all the other Justices of the Supreme Court agreed). Nevertheless, section 1(6) of the Landlord and Tenant Act 1988, also set out below, makes contrary provision in the context of that Act.[43]The amendments made to section 19 nearly seventy years later, in 1995, were consequential on the release of tenants under post-1995 leases from liability under lease covenants after assignment, which was effected by the Landlord and Tenant (Covenants) Act 1995, section 5. The 1995 Act amended section 19 of the 1927 Act by adding new subsections (1A) to (1E). According to Timothy Fancourt QC (as he then was), in his book The Enforceability of Landlord and Tenant Covenants, 3rd ed, 2014, [24-12], this was by way of partial compensation to landlords for the loss of original tenants’ liability on assignment of leases. Those subsections now permit the parties to non-residential leases to incorporate provisions in the lease specifying the circumstances in which consent can be withheld, or conditions can be imposed. These provisions do not apply to residential leases (as defined), presumably as a result of a perceived lack of bargaining power on the part of residential tenants.[44]For completeness, I add that section 1 of the Landlord and Tenant Act 1988 relevantly provides that: “(1) This section applies in any case where—(a) a tenancy includes a covenant on the part of the tenant not to enter into one or more of the following transactions, that is— (i) assigning, (ii) underletting, (iii) charging, or (iv) parting with the possession of, the premises comprised in the tenancy or any part of the premises without the consent of the landlord or some other person, but(b) the covenant is subject to the qualification that the consent is not to be unreasonably withheld (whether or not it is also subject to any other qualification). [ … ] (3) Where there is served on the person who may consent to a proposed transaction a written application by the tenant for consent to the transaction, he owes a duty to the tenant within a reasonable time— (a) to give consent, except in a case where it is reasonable not to give consent, (b) to serve on the tenant written notice of his decision whether or not to give consent specifying in addition— (i) if the consent is given subject to conditions, the conditions, (ii) if the consent is withheld, the reasons for withholding it. (4) Giving consent subject to any condition that is not a reasonable condition does not satisfy the duty under subsection (3)(a) above. (5) For the purposes of this Act it is reasonable for a person not to give consent to a proposed transaction only in a case where, if he withheld consent and the tenant completed the transaction, the tenant would be in breach of a covenant. (6) It is for the person who owed any duty under subsection (3) above— (a) if he gave consent and the question arises whether he gave it within a reasonable time, to show that he did, (b) if he gave consent subject to any condition and the question arises whether the condition was a reasonable condition, to show that it was,(c) if he did not give consent and the question arises whether it was reasonable for him not to do so, to show that it was reasonable, and, if the question arises whether he served notice under that subsection within a reasonable time, to show that he did.” (a) a tenancy includes a covenant on the part of the tenant not to enter into one or more of the following transactions, that is— (i) assigning, (ii) underletting, (iii) charging, or (iv) parting with the possession of, the premises comprised in the tenancy or any part of the premises without the consent of the landlord or some other person, but (b) the covenant is subject to the qualification that the consent is not to be unreasonably withheld (whether or not it is also subject to any other qualification). (a) to give consent, except in a case where it is reasonable not to give consent, (b) to serve on the tenant written notice of his decision whether or not to give consent specifying in addition— (i) if the consent is given subject to conditions, the conditions, (ii) if the consent is withheld, the reasons for withholding it. (a) if he gave consent and the question arises whether he gave it within a reasonable time, to show that he did, (b) if he gave consent subject to any condition and the question arises whether the condition was a reasonable condition, to show that it was, (c) if he did not give consent and the question arises whether it was reasonable for him not to do so, to show that it was reasonable,[45]This provision does not operate in the same way as section 144 or section 19, by inserting words into the lease, which then operate as part of the contract between the parties. Instead, it operates by way of statutory duty to give consent, except in limited circumstances. Then, breach of that duty is a tort sounding in damages: see section 4 of the 1988 Act. So, the section does not apply to our case. On the other side, a failure to comply with the proviso implied by section 19 is not a breach of statutory duty and does not sound in damages: Rendall v Roberts & Stacey (1960) 175 EG 265; Rose v Gossman (1967) 201 EG 767, CA. I was not addressed on the question whether the reversal of the burden of proof in section 1(6) applies, not only to the statutory tort created by the Act, but also to the provisions of section 19 of the 1927 Act. I therefore say nothing about it.[46]I was not referred to any case decided under section 19 to the effect that a landlord’s refusal to consent to alienation except on payment of a premium would be unreasonable. Indeed, there was no argument before me as to the circumstances in which it might be reasonable for a landlord to refuse consent. I have no wish to prejudice future cases, but (without deciding) I think it is possible, at least from an economic point of view, that such a refusal might not be unreasonable in a case(i) where the economic value of the grant of the lease as a property asset was shared between, say, (a) an initial premium for the grant, (b) a rent payable during the lease, and (c) a further premium for alienation of the lease if and when it had become more valuable, and(ii) where all this sharing was expressly provided for in the initial lease, so that the parties knew at the outset where they were.[47]In such a case the full market economic value of the lease would ultimately be paid to the landlord by the tenant, though probably in circumstances which more accurately represented the actual sequence of economic events with the asset. This would equally be the case if it were either the grant of a lease at rack rent with no premium (at either end), or the grant of a lease at a full premium at the outset, with no more than a nominal rent during the lease, and nothing on assignment. The practical difficulty in these cases is the possible lack of understanding of the parties (and particularly of the tenant), as to what obligations, present and future, they are engaging themselves for, which (in a perfectly functional system) ought to be resolved by adequate advice from legal professionals.[48]Nevertheless, I was referred to the statement of Hart J in Sims v Mahon [2005] 3 EGLR 87, [27], in the different context of a power to consent to plans under a freehold covenant, as follows:
“Nor can [the freeholder] refuse approval on grounds which are unrelated to the purpose for which the power has been reserved, for example that he simply does not like his neighbour. That too would be an obvious misuse of the power. So also would a refusal of approval not because there was in fact any objection to the proposals but because the covenantee wished to exact a monetary price for the giving of the approval.”
[49]Of course, there is no equivalent of section 144 (or, for that matter, section 19) which applies to freehold covenants, so that the circumstances in which Hart J said this were quite different to those obtaining here. I may say that in any event the last sentence is an obiter dictum, not necessary for the actual decision in that case. But I may also say that, with great respect to Hart J, I do not agree that it must necessarily be a misuse of a power to consent to alienation of an asset to do so conditionally on payment of a premium. If, as set out above, it were part of the economic price for which the asset were transferred (and subject to any other public policy rules applicable to similar assets), I do not see why that should necessarily be a misuse of power. Of course, Hart J was dealing with the case of a freehold, rather than a lease, and usually the entire economic value of a freehold is paid on completion of a sale and purchase. Leases are however more complex.[50]In this context, I note the provisions of section 123 of the Local Government Act 1972, which relevantly read:
“(1) Subject to the following provisions of this section, [and to those of the Playing Fields (Community Involvement in Disposal Decisions) (Wales) Measure 2010,] a principal council may dispose of land held by them in any manner they wish. (2) Except with the consent of the Secretary of State, a council shall not dispose of land under this section, otherwise than by way of a short tenancy, for a consideration less than the best that can reasonably be obtained.”
[51]A “principal council” is defined by section 270(1) of the 1972 Act as “a council elected for a principal area”, which also defines a “principal area” as “a [non-metropolitan county], a district or a London borough … ” Thus, both of the defendants are “principal councils”.

Implied repeal

[52]As I have indicated, the interplay between section 144 of the 1925 Act and section 19 of the 1927 Act is central to my decision in this case. Both provisions deal with covenants restricting alienation of leases. The former deals with the possibility of the landlord’s requiring a premium for consent to alienation. The latter deals with landlord’s consent more generally, in particular turning qualified into fully-qualified covenants. The relationship between section 144 and section 19 is not regulated by the express terms of either, such as an express repeal or variation of part of the former by the latter. So, I will need to consider the possibility of implied (partial) repeal of the former by the latter. As to this, in Kutner v Phillips [1891] 2 QB 267, AL Smith J said (at 271-272) that:
“Now a repeal by implication is only effected when the provisions of a later enactment are so inconsistent with or repugnant to the provisions of an earlier one that the two cannot stand together, in which case the maxim, ‘Leges posteriores contrariasabrogant’, applies. Unless two Acts are so plainly repugnant to each other that effect cannot be given to both at the same time a repeal will not be implied and special Acts are not repealed by general Acts unless there is some express reference to the previous legislation, or unless there is a necessary inconsistency in the two Acts standing together.”
[53]This statement was relied on in more recent times by Laws LJ in O'Byrne v. Secretary of State for Environment, Transport and the Regions [2002] HLR 30, CA, where he said that:
“68. … the respondent inevitably accepts that if there is an inescapable logical contradiction between the earlier and the later statute, the former is repealed by implication. But the contradiction asserted must be inescapable; so that where (as here) an implied repeal is said to be based on the construction of the later statute, that construction must be shown to be the only rational interpretation which is available.”
This reasoning was followed by the Court of Appeal in Snelling v Burstow Parish Council [2014] 1 WLR 2388, [36]-[38], and was recently approved by the Privy Council in Henry v AG of Saint Lucia [2023] UKPC 41, [37]. There is accordingly a high threshold to get over for an implied repeal to be held to have taken place.[54]AL Smith LJ, in the last four lines of the extract from Kutner v Phillips cited above, also referred to a second interpretative principle that “special Acts are not repealed by general Acts” except in certain limited cases. This principle always used to be rendered in Latin as generalia specialibus non derogant, and it is still sometimes cited in this way even nowadays. Thus, in R (Newhaven Port & Properties Ltd) v East Sussex County Council [2015] AC 1547, SC, Lord Neuberger and Lord Hodge (with whom Lady Hale and Lord Sumption agreed) said:
“93. … Where there is a conflict between two statutory regimes, some assistance may be obtained from the rule that a general provision does not derogate from a special one (generalia specialibus non derogant), which is set out in section 88 of the code in Bennion, ‘Statutory Interpretation’ 6th ed (2013): ‘Where the literal meaning of a general enactment covers a situation for which specific provision is made by another enactment contained in an earlier Act, it is presumed that the situation was intended to continue to be dealt with by the specific provision rather than the later general one. Accordingly the earlier specific provision is not treated as impliedly repealed’.” ‘Where the literal meaning of a general enactment covers a situation for which specific provision is made by another enactment contained in an earlier Act, it is presumed that the situation was intended to continue to be dealt with by the specific provision rather than the later general one. Accordingly the earlier specific provision is not treated as impliedly repealed’.”

Use of Parliamentary materials as an aid to construction of legislation

[55]The final point of law which I should set out relates to the circumstances in which it is open to the court to have regard to Parliamentary debates as an aid to construction of legislation. The modern position was set out in Pepper v Hart [1993] AC 593, HL. A recent exposition of the principle was given by the Supreme Court in Re an application by JR222 for Judicial Review [2024] 1 WLR 4877, where Lord Stephens (with whom the other Justices agreed) said:
“78. In this appeal, the respondent relies on reports in Hansard as to the legislative debates during the passage of the Bill which led to the enactment of the Act as an external aid to interpretation. Under the rule in Pepper v Hart [1993] AC 593, the court may have regard to reports of the legislative debates on a Bill for the purpose of ascertaining the meaning of a provision of the resulting Act where three critical conditions are met. The three critical conditions are (i) that the legislative provision must be ambiguous, obscure or, on a conventional interpretation, lead to absurdity; (ii) that the material must consist of or include one or more statements by a minister or other promoter of the Bill; and (iii) the statement must be clear and unequivocal on the point of interpretation which the court is considering.”
It is not necessary for me to refer to any other part of the decision in that case.

The view of the Law Commission

[56]An important part of the law of leasehold covenants was examined by the Law Commission, and was the subject of its 1985 Report on Codification of the Law of Landlord and Tenant: Covenants Restricting Dispositions, Alterations and Change of User, Law Cssn 141. At that time, the Chairman of the Law Commission was Sir Ralph Gibson, later a Lord Justice of Appeal, and the other members were Trevor Aldridge (later an honorary QC, and whose project this was), Brian Davenport QC, Prof Julian Farrand, and Prof Brenda Hoggett (later Baroness Hale of Richmond). I was referred to a number of individual paragraphs in this Report. In order that these may be placed in context, I consider it sensible to set out here the principal paragraphs dealing with the legislative provisions with which I must deal, namely section 144 of the 1925 Act and section 19 of the 1927 Act. Section 144 of the 1925 Act[57]The 1985 Report said this about section 144:
“3.9. In this paragraph we consider the effect of this section as it originally stood before the enactment of section 19(l)(a) of the Landlord and Tenant Act 1927, which made further provision as to disposition covenants. We deal later with section 19(l)(a) and when we do so we shall reconsider the points made below. (1) It should be noted, first, that the section has no effect at all when a disposition covenant is absolute. (2) Even when the covenant is not absolute, the section will not in practice always prevent a fine being taken. It does not make it illegal for the landlord to ask for one, and if the tenant pays it (either because he does not know his rights or because he considers it the easiest course to take), the fine cannot be recovered. (3) More important, the section contains nothing to turn a qualified covenant into a fully qualified one. There is therefore nothing to prevent a landlord who has taken a qualified covenant from withholding his consent altogether (however unreasonably) and telling the tenant that if he wants to make the disposition he will have to surrender his existing tenancy and take a new one which allows dispositions, and that he must pay a premium in order to obtain it. The premium, of course, will be only a fine called by another name. (4) It seems, therefore, that the section isreally effective only in the case of a fully qualified covenant. Paradoxically, however, it can be argued that this is the one case in which its provisions are unnecessary because the courts would almost certainly have held that the demand of a fine for giving consent amounted to an unreasonable withholding. (5) Finally, it is arguable that the section does not apply at all when the disposition which the tenant wants to make is a disposition of only part of the premises let.”

Section 19 of the 1927 Act

[58]In relation to section 19(1), the Law Commission said this:
“3.15. The first and most important provision (in sub-section (l)(a)) subjects such covenants to an implied proviso that the consent is not to be unreasonably withheld. Like section 144, it adds that the proviso is not to prevent the landlord requiring a reasonable sum for expenses. But unlike section 144 it stipulates that the proviso applies despite any provision to the contrary. The main effect of this is to convert qualified covenants automatically into fully qualified ones. 3.16. Having summarised section 19(l)(a), it is appropriate to reconsider, in the light of it, the points made in the numbered sub-paragraphs of paragraph 3.9 of this report in relation to section 144 sf the Law of Property Act 1925: (a) Section 19(l)(a) makes no difference to sub-paragraphs (1)or (it seems) (2) of that paragraph. (b) Sub-paragraph (3), however, is no longer valid (except for agricultural tenancies, to which section 19(l)(a) did not apply) in that there are (except in them) no longer any disposition covenants which are qualified but not fully qualified. (c) For this reason there is, on the argument put forward in sub-paragraph (4), an increase in the number of cases in which section 144 is fully effective but also unnecessary. In fact the suggestion that section 144 is unnecessary where the covenant is fully qualified is perhaps strengthened by section 19(l)(a) because the wording of its ‘fully qualifying’ proviso conveys the clear impression that the demand of a fine would in principle be unreasonable: otherwise there would be no need to include (as the proviso does) an express saving for landlords who require payment of their reasonable expenses. (d) It can even be argued that the only surviving effect of section 144 (except for agricultural tenancies) may be to lessen the protection given to the tenant by section 19(l)(a). The proviso implied by that paragraph (which clearly suggests, as we have just said, that it is unreasonable to demand a fine) applies despite any contrary provision in the tenancy. Section 144, by contrast, can be nullified by such a provision. So what would happen if a case arose in which an expressly qualified or fully qualified covenant were coupled with an express provision for a fine? It might be said that section 19(l)(a) had rendered nugatory the right to contract out contained in section 144 and this is probably correct. But section 144 remains on the statute book; and although its continued presence is explicable on the ground that it is still needed for agricultural tenancies, it has not been limited to such tenancies but remains quite general. So it might conceivably be concluded that the right of contracting out was still excusable, with the result that the provision for a fine remained valid. (e) As to sub-paragraph (3),it should be noted that section 19(l)(a) applies equally to dispositions of part as to those of the whole. If the argument in sub-paragraph (d) above is valid, therefore, the strange result might be that the protection conferred by section 19(l)(a) is greater in relation to dispositions of part (to which section 144 arguably does not apply) than it isin relation to dispositions of the whole (where it may still have an effect).”
[59]I think that I should also set out two later paragraphs concerning recommendations of the Law Commission:
“8.20. Allowing a landlord to demand a fine for giving consent – that is, a payment or other consideration just for the consent itself – would be wholly inconsistent with the nature of a fully qualified covenant. It would go against the policy which has led to the recommendations for full qualification, and it would go far to deprive those recommendations of practical effect. In no case could it be reasonable for a landlord to withhold consent upon the ground that the tenant had refused to pay a fine, and this should be made clear. [ …] 8.22. … as we mentioned earlier (ie paragraph [3.16(d)], there is a possibility, because of a provision in section 144 of the Law of Property Act, 1925,that contracting out may be effective under the present law in relation to certain fully qualified disposition covenants. We recommend that any doubt which may exist on this point should be removed.”
[60]These paragraphs (and others in the same part of the Report) set out the arguments which had persuaded the Commission to make its recommendations, including one that premiums for giving consent to alienation should be forbidden, as in the last sentence of paragraph 8.22. They were saying that this might already be the law, but that legislation should put the matter beyond doubt. Unfortunately, Parliament did not do so, and I now have to decide the same question. The parties’ cases Defendants

The parties’ cases

[61]It will be helpful at this point for me to set out a broad idea of each side’s case, in order to provide a context for summarising their submissions. For ease of exposition, it is convenient to summarise the defendants’ case first. This falls into two parts. The first is that clause 3.9.4 of the New Leases is not affected by section 19(1) of the 1927 Act, because section 144 of the 1925 Act applies and creates what they call a “carve-out” from the full-qualification that would otherwise be achieved by section 19(1). This “carve-out” saves lease terms expressly permitting landlords to extract a premium as the price for a consent for an assignment. I would prefer to express the submission as one simply that section 144, and not section 19, applies to the provisions in the Leases enabling a premium to be charged for consent to alienation. The second part is that, if the defendants are wrong about the first point, they can rely upon section 19(1A), given that, for the purposes of sub-section (1E), the Leases (they say) are not “residential lease[s]”. Claimants[62]The claimants’ case is also simple. It is that section 144 of the 1925 Act is irrelevant, and section 19 applies. Moreover, the New Leases are “residential leases” within section 19(1E) and so section 19(1A) is not satisfied. Therefore, clause 3.9.4 of the Leases (set out earlier) is overridden by section 19(1) of the 1927 Act. As a result, the New Leases contain standard fully-qualified alienation covenants under which the defendants cannot make the grant of consent for an assignment conditional on the payment of the stipulated (or any other) premiums. This implies that a provision for a premium to be charged for consent to alienation infringes the proviso for consent not to be unreasonably withheld. Issues to determine[63]It will be seen that the first part of each side’s case depends on the interaction between section 144 of the 1925 Act and section 19 of the 1927 Act. Accordingly, there are up to three sub-issues that I may have to determine. The first (in any event) is whether, in non-agricultural leases, section 144 applies to this case (so allowing for premiums to be charged on consent to alienation) despite the full qualification to the consent provision that would otherwise be obtained by the application of section 19. The defendants say that it does. The claimants say that it does not, and that instead section 19 applies. The second sub-issue arises only if the claimants are right and section 19 does apply to this case. The second sub-issue is whether the New Leases in this case are or are not “residential leases” within section 19(1E). The defendants say that they are not, and clause 3.9.4 has effect (so concluding the question of reasonableness in the application of the proviso), whereas the claimants say that they are, and so clause 3.9.4 has no effect. If the claimants are right, then a third sub-issue may arise, and that is whether the premium provisions amount to unreasonably withholding consent within section 19(1) in relation to any of the New Leases. (This is explained further below.) It is fair to say that the oral argument before me concentrated on the first two sub-issues only, though the further written submissions also dealt to some extent with the third. And no evidence was adduced on the position of individual claimants in relation to their own leases. The parties’ submissions The first sub-issue: defendants[64]I will begin by summarising the defendants’ submissions. The defendants say that a lease can lawfully provide for a premium to be paid on assignment, as a condition of consent to the assignment, by virtue of section 144 of the 1925 Act and section 19 of the 1927 Act. Section 144 has never been repealed, and still applies to all leases, business and residential. So, it still allows such premiums, and section 19 does not diminish its potency. They refer to the decision of David Casement QC in Burrell v Helical (Bramshott Place) Ltd [2015] EWHC 3727 (Ch). The New Leases took advantage of this possibility, and expressly provided for such a premium, as part of the entire bargain between the parties, which also included permitting the tenants to make holiday lettings of their huts or chalets, and contracting out of the Landlord and Tenant Act 1954, Part II. The tenants entered into the New Leases with their eyes wide open, and should not be able to renege on their bargain. The first sub-issue: claimants[65]On the other side, the claimants give five reasons for arguing that the defendants are wrong to say that section 144 “creates a carve-out from the full qualification otherwise achieved” by section 19. In summary form, these five reasons are:(1) The “straightforward and unambiguous meaning” of the two provisions is that there is no “carve-out”. Section 144 imports a proviso to a covenant for landlord’s consent that no fine shall be payable for consent unless the lease contains an express provision to the contrary. But these leases do. So, section 144 does not apply, and there is no such proviso imported. Meanwhile, section 19 subjects the alienation covenants in non-agricultural leases to a proviso that consent not be unreasonably withheld, which (in light of the purpose of alienation covenants, as set out above by Balcombe LJ) overrides the terms of the New Leases enabling the defendants to grant consent to alienation conditional on payment of a premium.(2) Given the direction of travel of the legislation since 1892 (increasing restrictions on landlords’ ability to cut down tenants’ freedom to alienate their leases) it is not surprising that section 19 rendered section 144 “partly otiose”, that is, ineffective in respect of non-agricultural tenancies. Since 1927, section 144 accordingly has had effect only in relation to agricultural tenancies.(3) A carve-out from section 19 would be illogical, in that it would mean that the section did not override a lease term derogating from full-qualification by permitting consent to be granted conditional on payment of a premium (although it would do so for all other such derogations). Yet section 144, which would have created the carve-out, was enacted in order to protect tenants from attempts by landlords to extract premiums for consent to alienation.(4) Section 19(1) contains an exception to the prohibition on the landlord’s demanding money for consent, in that the landlord may “require a reasonable sum for legal or other expenses incurred” in connection with the transaction. This shows that Parliament intended a general prohibition on landlords making consent conditional on the payment of money.(5) The Law Commission, in its 1985 Report, considered that there was “probably” no such carve-out, at [3.16](d), set out previously, but the material terms of which I repeat here for ease of reference:
“ … So what would happen if a case arose in which an expressly qualified or fully qualified covenant were coupled with an express provision for a fine? It might be said that section 19(1)(a) had rendered nugatory the right to contract out contained in section 144 and this is probably correct. But section 144 remains on the statute book; and although its continued presence is explicable on the ground that it is still needed for agricultural tenancies, it has not been limited to such tenancies but remains quite general. So it might conceivably be concluded that the right of contracting out was still excusable, with the result that the provision for a fine remained valid.”
The second sub-issue: defendants[66]As previously set out, the phrase “residential lease” is defined by section 19(1E) of the 1927 Act as “a lease by which a building or part of a building is let wholly or mainly as a single private residence”. The defendants’ submissions on the second issue, in summary, are the following:(1) The New Leases do not let any buildings; instead they let the plots alone;(2) The Leases prohibit the use of any buildings that are erected on the plots as dwellings and residences;(3) The Leases allow business activity which could not arise if they were residential leases;(4) The Leases allow multiple occupation and so are not leases for a single residence;(5) The Leases allow more than one building on each plot, and so multiple occupation, which is not a letting ‘wholly or mainly as a single private residence’;(6) The Leases allow buildings to be used for business activities (holiday lets) for 45% of each year and so are not “wholly or mainly” let as a single private residence;(7) The Leases forbid continuous occupation throughout the year (because there is one month each year when there can be no occupation), and so do not let the plots as a residence. The second sub-issue: claimants[67]The claimants say that there are three reasons why the New Leases are not “residential leases” within the meaning of that subsection. These can be summarised as follows:(1) A “residential” lease can be contrasted with a “business” lease. But the New Leases are not “business” leases.(2) The purpose of the exclusion is to protect residential tenants, on the basis that they are likely to be in a weaker position than business tenants. So the exclusion should extend to leases of holiday homes. The claimants refer to Phillips v Francis [2010] L&TR 28, dealing with leases of holiday chalets, which were held to be covered by the provisions regulating service charges in the Landlord and Tenant Act 1985, section 18.(3) On a close textual analysis of the definition, the New Leases fall within it. The chalets are obviously buildings. Whilst it is a matter of construction of the terms of the lease concerned, in the present case each chalet was let as a single rather than multiple occupation unit. And similarly each chalet was let as a private residence. The claimants refer to decided cases in connection with this last point: C & G Homes Ltd v Home Secretary [1991] Ch 365 (“care in the community” lettings: breach of covenant); Nemcova v Fairfield Rents Ltd [2017] 1 P & CR 4 (AirBnB lettings: breach of covenant). Discussion Hypothetical question?

Discussion

[68]I begin my discussion with the question whether what I am being asked to decide is too hypothetical to be answered. The declarations sought are(i) that “Clause 3.9.4 of the Leases is void”, and(ii) that “The Defendants are not entitled to make grants of consent for assignments of the Leases subject to a condition requiring the payment of a premium”.[69]Cockerill J in the BNP Paribas case said that the court “will not pronounce upon legal situations which may arise, but generally upon those which have arisen”. Here I am not asked to say whether the defendants may charge this or that tenant a premium on assignment. No case of assignment has been put forward for my decision. Indeed, in the nature of things, it is at least theoretically possible that none ever will take place. Probably, many of the 21 year leases will expire without being assigned.[70]Cockerill J also said that “There must in general, be a real and present dispute between the parties before the court as to the existence or extent of a legal right between them”, and that “If the issue in dispute is not based on concrete facts the issue can still be treated as hypothetical”. In my judgment, there is a real dispute between the parties as to the status of clause 3.9.4, and in these circumstances I can properly be asked to say whether I should grant declaration (i). It is a question of law to which the parties wish to know the answer so as to govern their future conduct with each other. But I do not see at present how I can deal with the second declaration sought. It depends on circumstances which have not arisen, may never arise, and ex hypothesi cannot be the subject of evidence in individual cases. Nevertheless, I will deal with as much of the dispute between the parties as I think I can.

The first sub-issue

[71]The first sub-issue concerns the relationship between section 144 and section 19. Are the two provisions inconsistent, and, if so, did the later section 19 impliedly repeal the earlier section 144 to the extent of the inconsistency? In the present case, both sides say that the threshold for implied repeal has not been reached. Nevertheless, and as I have said, the claimants go on to to say that section 19(1) has rendered section 144 (partly) “otiose”. This is because (it is said) section 19(1) applies to all leases containing a covenant against assigning, etc, without consent, except certain agricultural tenancies (see section 19(4)). Meanwhile, section 144 applies to all leases containing a covenant against assigning, etc, where the lease does not contain a provision negating the proviso otherwise implied (that no premium shall be payable for such consent). Hence section 144 applies only to leases for certain agricultural tenancies containing a covenant against assigning, etc, the whole premises where there is no express provision to the contrary. For my part, I do not see why this (if correct) is not the same as an implied repeal of the rest of the section, but I need not deal with that now. The fact is that the claimants say that the rest of section 144 no longer applies.[72]Meanwhile, the defendants say that there is no sufficient inconsistency between section 144 and section 19, and that both can operate in their respective spheres. Section 144 allows provision for consent to be given to alienation of a lease conditional on a premium being paid, as long as it is expressed in the lease, and section 19 effectively turns qualified into fully-qualified covenants. In the New Leases, there is indeed such provision, and section 144 is expressly referred to.[73]The claimants say there are five reasons why the defendants’ conclusion is wrong (see [65] above). Of those reasons, the fourth and fifth seem to me to be makeweights. The fourth is the existence of an exception in all cases for reasonable legal and other expenses. But I do not think that this exception shows that Parliament intended a general prohibition on landlords making consent conditional on the payment of money. There are always transaction costs. At best it is neutral.[74]The fifth is the opinion of the Law Commission in 1985. Yet there is little reasoning given for the opinion (there is no reference, for example, to the question of implied repeal), and even so the Commission expresses some doubt on the matter. I am not assisted by this. As Patten LJ (with whom Hamblen and Henderson LJJ agreed) said in Goulandris v Knight [2018] 1 WLR 3345, [13], in relation to a considered statement of the law on service of documents in an official Government impact statement, “ … it seems to me that for the purpose of construing section 15little or no weight can be attached to the fact that most members of the profession together with the Government itself considered that the valid methods of service for the purposes of the 1996 Act were restricted to those set out under section 15or at least did not include service by electronic means. That is a question of statutory construction on which there is no direct authority and which turns on the wording of section 15 itself looked at in context having regard to the purpose of the provision … [I]n itself the position taken by the Government provides no additional authority for treating section 15 as an exhaustive code and the judge was wrong in my view if he treated it as persuasive let alone decisive in relation to the question of construction on the preliminary issue.”[75]But there is perhaps more to the first three reasons. The first reason is that, because section 144 imposes a proviso unless there is express provision to the contrary, and in this case there is such express provision, the effect of section 144 is exhausted, and so section 19 applies in full. The second is that the direction of travel of the legislation since 1892 is to increase restrictions on landlords’ ability to cut down tenants’ freedom to alienate their leases, which supports the idea that section 19 should apply whenever section 144 does not. The third is that the purpose of section 144 was to protect tenants from attempts by landlords to extract premiums for consent to alienation, but here it would be used to defeat that protection.[76]The problem with these submissions is that they do not really grapple with the fact that section 144 and section 19 are two statutory provisions dealing with restraints on alienation of leases, but apparently dealing with different aspects of them. Section 144 is concerned with the ability of the landlord to charge a premium for consent to alienation. This is dealt with by a bright line rule: either there is an “opt-out” in the lease, an express provision to the contrary, or there is not. If the former, a premium can be charged. If the latter, a premium cannot. The section does not deal with any other kind of restraint on alienation. It is specific to premiums. Section 19, on the other hand, is general, and appears to apply to all kinds of such restraints. It does not provide a bright line rule, but instead imports the standard of reasonableness, which requires consideration of all relevant circumstances.[77]In my judgment, section 144 is clear and unambiguous. That being so, I am not at liberty to construe it by reference to what Parliament has said about the same subject on a subsequent occasion. For example, in Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 2 KB 403, 414, Lord Sterndale MR said:
“ … subsequent legislation on the same subject may be looked to in order to see what is the proper construction to be put upon an earlier Act where that earlier Act is ambiguous. I quite agree that subsequent legislation, if it proceed upon an erroneous construction of previous legislation, cannot alter that previous legislation; but if there be any ambiguity in the earlier legislation then the subsequent legislation may fix the proper interpretation which is to be put upon the earlier.”
This dictum was approved by Sir Geoffrey Vos, C, with whom Flaux and Newey LJJ agreed, in DSG Retail Ltd v Mastercard Inc [2020] EWCA Civ 671, [57].[78]The claimants rely on section 19(1) as overriding any attempt to water down “full” qualification of the consent requirement. They say that it renders inconsistent provisions void. They cite three first instance decisions, Balfour v Kensington Gardens Mansions Limited (1932) 49 TLR 29 (Macnaghten J), Creery v Summersell [1949] Ch 751 (Harman J), and Smith v Richards [1951] 1 All ER 346 (Roxburgh J). But all three of these cases are ones of simple covenants against assigning, etc, without consent. None of them involved a covenant requiring a premium to be paid. Accordingly, none of them can be an authority on the precise question arising here.[79]In the absence of any binding authority, I therefore plough the field afresh. Logically, there are three possibilities. The first is that the two provisions are inconsistent, and section 19 has repealed section 144 to the extent of the inconsistency. The second is that they are not inconsistent, because section 144 deals with premiums for consent to alienation in qualified covenants, and section 19 deals with all other aspects of such consent. The third is that they are not inconsistent, and both sections apply to premiums for such consent, whereas only section 19 applies to non-premium consent cases. In the third case, a premium requirement would not only have to be expressed in the lease (to satisfy section 144), but would also have to be not unreasonable in the circumstances (to satisfy section 19). But ex hypothesi it would not automatically follow that every premium would be unreasonable, otherwise the sections would indeed be inconsistent.[80]Having considered the matter, I am not persuaded that the two provisions are inconsistent. The Parliament of 1924 to 1929 passed both Acts of Parliament, just two or three years apart. The bill of 1891, which became the Act of 1892, originally contained both provisions, though it appears that one was dropped because of landlord opposition. The remainder of section 3 of the 1892 Act was consolidated into the 1925 Act, and then the 1927 Act was passed, a generation late, so to speak, to include the provision dealing generally with restraints on alienation. Section 144 deals with the ability of the landlord to charge a premium for consent to alienation. Section 19 deals with all other aspects of restraints on alienation. It is difficult to suppose that Parliament in enacting section 19 in 1927 intended to vary or amend section 144 enacted two years earlier. I agree that the direction of travel is one way, but it does not follow that the general rule in section 19 should abrogate the specific in section 144. Since there are at least two other rational possibilities, I consider that there is no inescapable inconsistency between them. Instead, I should attempt to construe the two provisions so that there is no inconsistency between them.[81]That is enough to avoid any possibility of an implied repeal of the earlier provision by the later. As Laws LJ said in the O’Byrne case, cited earlier, “the contradiction asserted must be inescapable; so that where (as here) an implied repeal is said to be based on the construction of the later statute, that construction must be shown to be the only rational interpretation which is available.” This conclusion is supported also by the fact that section 144 is dealing with a specific aspect of the subject, whereas section 19 is dealing with the subject generally. General provisions do not derogate from special provisions without a good reason. I see none of sufficient force here.[82]So, section 144 applies in full. The next question is more difficult. Did Parliament intend that after 1927 both section 144 and section 19 would apply to premium covenants, or only section 144? The claimants say not. On their view, the effect of section 144 is exhausted by the inclusion of the provision to the contrary in clause 3.9.4, and so only section 19 applies to the premium covenant in the new leases.[83]The defendants, on the other hand, say that Parliament did intend that both sections 144 and 19 should apply. They cite the decision in Burrell v Helical (Bramshott Place) Ltd [2015] EWHC 3727 (Ch). This case concerned leases of homes in a retirement village. The leases contained a provision for payment of a premium on alienation. The decision was one on an application to strike out a claim under the Consumer Credit Act 1974. The claim alleged that, by deferring a payment by the tenant to the landlord under the alienation provisions of the lease, the landlord was providing credit to the tenant, but that the requirements of the 1974 Act had not been met. The deputy judge held that this was not the provision of credit within the 1974 Act, and so struck out the claim.[84]However, neither section 144 of the 1925 Act nor section 19 of the 1927 Act was even cited in that case, let alone discussed. It was not about those provisions, nor about the interplay between them. Accordingly, this decision does not assist me in resolving that question, except to the extent that it shows that there may well be cases where a premium on future assignment is intended to make up part of the purchase price on a certain contingency, akin to an overage clause in a contract for the sale of land to be developed: see at [35]-[36] of the judgment.[85]The fact, already noted, that section 144 deals with a specific aspect of the subject, whereas section 19 deals with the subject generally, might tend to suggest that they were intended to operate separately, each in its own domain. On the other hand, as the claimants say, the direction of travel has been in favour of greater restriction of the landlord’s ability to place fetters on the tenant’s ability to alienate. So, it is not implausible in 1927 that Parliament may have wished to continue the existing specific rule for premiums, requiring express notice of them in the lease, and yet, even where they were permitted, to subject them to a test of reasonableness.[86]In this regard I note that, in moving the second reading in the House of Lords of the bill that became the 1927 Act, on 29 November 1927, Viscount Cave LC said this (Lords Hansard, vol 69 col 314):
“As to the restrictive covenants against assigning, altering or improving premises or changing the use of them without consent, I have said that some landlords do make unreasonable use of those covenants and do exact fines for giving their consent. First there is the covenant against assigning or underletting without consent. There is already a statutory provision against exacting a fine for consent to an assignment or underletting. That has been the law since, I think, the year 1881. It is also common in well-drawn leases to provide that assent shall not be unreasonably withheld. We propose to read that condition, that consent shall not be unreasonably withheld, into every covenant of this kind.”
[87]It will be seen that the Lord Chancellor was in slight error as to the year of the law already dealing with premium clauses (1881 instead of 1892), This is no doubt to be explained by the fact that the long title of the 1892 Act was “An Act to amend the Conveyancing and Law of PropertyAct, 1881”. but otherwise it is clear that the Government’s intention was to apply the requirement of reasonableness across the board. The claimants say that nothing in sections 144 and 19(1) is “ambiguous or obscure”, and that therefore the requirements of Pepper v Hart [1993] AC 593 are not satisfied. I agree about section 144. But I disagree about section 19(1). The claimants say that the alienation covenants in the New Leases are made subject to the section 19(1) proviso, and that they “cannot think of any other way in which it could even be argued that the statutory language operates” (emphasis in original). I do not accept that. For example, the defendants argued that there was a “carve out” from section 19 for section 144, that is, that section 144 applied to covenants concerning premiums to be paid on assignment, etc, whether or not section 19 applied to all other covenants on assignment, etc.[88]In my judgment, the statement of Viscount Cave LC satisfies the three conditions laid down by the House of Lords in Pepper v Hart. The provisions of section 19 are ambiguous as to whether they relate to premium covenants or not, the statement is made by the Government minister moving the second reading the bill, and the statement is clear. I am therefore entitled to take this statement into account in construing that section.[89]Having done so, on the material before me, I am persuaded that section 19 was intended by Parliament to apply even to the ability of the landlord to charge a premium for consent to alienation. In other words, both section 144 and section 19 apply to a premium covenant. So, section 19 does apply in principle. However, section 19(1A) now provides that, where the circumstances for the premium to be charged for consent to alienation are set out in the lease, the condition is deemed to be not unreasonable. The New Leases undoubtedly do set out such circumstances (referring expressly to section 19 for this purpose). But the application of section 19(1A) in the present case depends on whether the Leases are or are not “residential leases” within section 19(1E). This is the second sub-issue. I therefore turn to consider this question. The second sub-issue[90]The defendants had seven reasons for submitting that the New Leases were not residential leases within section 19(1E). The first of these reasons has fallen away, since I have proceeded on the basis that the leases included the chalets and huts, which were previously agreed to be fixtures, although the defendants unsuccessfully sought to row back on that. The New Leases are leases of the plots of land and the buildings that were fixtures on the land at the time that they were granted.[91]The second reason is said to be that the New Leases prohibit the use of any buildings that are erected on the plots “as dwellings and residences”. But this is not quite the case. Clause 3.7 of each New Lease relevantly provides that the chalet or hut shall not be used “as the only or main residence of any person or otherwise used as a dwelling”. The “only or main” residence stipulation does not mean that it cannot be a residence. It is well established that a person may have more than one residence: see eg Williams v Horsham DC [2004] 1 WLR 1137, [26], CA; Islington LBC v Boyle [2012] PTSR 1093, [56], CA.[92]The “otherwise used as a dwelling” stipulation is at first sight odd, because the chalets and huts are obviously constructed so as to be capable of being lived in, day and night, and other lease terms contemplate the subletting of the chalets and huts for the purpose of short-term holidays, which involves a continuous stay in the chalet or hut. In Uratemp Ltd v Collins [2002] AC 301, HL, a decision on section 1 of the Housing Act 1988, Lord Millett (with whom Lord Irvine LC, Lord Steyn and Lord Hobhouse agreed, said:
“30 The words ‘dwell’ and ‘dwelling’ are not terms of art with a specialised legal meaning. They are ordinary English words, even if they are perhaps no longer in common use. They mean the same as ‘inhabit’ and ‘habitation’ or more precisely ‘abide’ and ‘abode’, and refer to the place where one lives and makes one's home. They suggest a greater degree of settled occupation than ‘reside’ and ‘residence’, connoting the place where the occupier habitually sleeps and usually eats, but the idea that he must also cook his meals there is found only in the law reports. It finds no support in English literature … ”
[93]In my judgment, the phrase “as a dwelling” in the New Leases must be construed so as not to interfere with the recreational or holiday purpose, for which they were expressly granted, of staying there, day and night, for short periods. In this sense “dwelling” must mean something more permanent, such as staying there continuously for months at a time, or even indefinitely. For the purposes of this case, however, it is not necessary to decide exactly how long that might be. It is only necessary to hold that each of the Plots can be occupied as a residence, which, as Lord Millett observed, connotes a lesser degree of occupation than “dwelling”.[94]The third reason is that the New Leases (by clause 3.9.7) allow the business activity of short-term holiday lettings. The defendants rely on Triplerose Ltd v Beattie [2020] HLR 37, UT, as authority for the proposition that “the contractual entitlement to holiday let means that the Plots are not being let as a private residence”. In that case the lessees of a residential flat in a purpose-built block moved away, and ceased to live continuously in the flat. It was let for short-term stays of a few days at a time, and a local company provided a check-in and check-out service and fresh laundry. One of the lessees occupied the flat every week over two or three nights. The lessor sought a determination that the lessees were in breach of a covenant in the following terms:
“Not at any time to carry on or permit to be carried on upon the Property any trade or business whatsoever nor to use or permit the same to be used for any purpose other than as a private dwelling house for occupation by one family at any one time.”
[95]The Upper Tribunal (Martin Rodger QC) held that there had been no breach of that part of the covenant preventing the carrying on of any trade or business, but that there had been a breach of that part preventing the property from being used otherwise than as a private residence.

The judge said:

“20. … the use of residential property for short term occupation by a succession of paying guests has always been treated as a breach of a covenant requiring use only as a private residence or dwelling-house. Occupation by a sub-tenant who uses the property as his or her own private residence is permitted, as may be occupation by a group of individuals living collectively, or by non-paying guests, family members, or servants occupying with the tenant. But short-term occupation by paying strangers is the antithesis of occupation as a private dwelling-house. It is neither private, being available to all comers, nor use as a dwelling-house, since it lacks the degree of permanence implicit in that designation.”
[96]However, in that case there was no provision in the lease contemplating short-term holiday lettings. Here there is an exception for such lettings. This provision obviously permits that activity, and means that there can be no breach of the covenant against permitting user otherwise than as a private dwelling by doing that which is expressly permitted. I accept that the defendants are not suggesting that there would be a breach of covenant by subletting for holiday purposes. They are saying that this means that the New Leases are not “residential leases” within section 19(1E), ie that the Plots are not “let wholly or mainly as a single private residence”. Yet that was not the question which the judge was deciding in Triplerose Ltd v Beattie, and he said nothing about the question now before me. Accordingly, I do not derive any assistance from that decision. On the face of it, the Plots were let “mainly as a single private residence”. The short-term occupation by third parties for holiday purposes was incidental to the main purpose, which was occupation as a single private residence.[97]The defendants say that, if you use the whole property for a different (business) purpose, then you cannot call it use as a private residence. Here the lease permits subletting for holidays for up to five months a year (out of the eleven for which it can be occupied at all). That would be a substantial inroad on use as a private residence. But, apart from the fact that that is what the lease itself contemplates, that is the absolute maximum. In practice, the inroad is likely to be much less. And the lease both requires use as a private residence and permits holiday subletting for just five months, which is still less than the remaining six months of the year during which occupation without any subletting is permitted. Over the course of a year, and a fortiori over the 21-year term of the lease, it is still let “mainly as a single private residence”. In my judgment, the fact that, during the short time it is sublet for a holiday, it is not then being occupied as a private residence is in the circumstances neither here nor there.[98]The defendants refer to the decision in R v Radio Authority, ex p Bull [1998] QB 294. Here, the Court of Appeal considered the meaning of the phrase “wholly or mainly of a political nature” in the Broadcasting Act 1990, section 92(2)(a)(i). The question arose in the context of restricting advertising on the radio by bodies of such a nature. It had nothing to do with leases. Lord Woolf MR (with whom Brooke LJ agreed) See his judgment at 314G. Aldous LJ gave a concurring judgment, in which he said (at 311C) that “the words ‘wholly or mainly’ are words of degree. They are not coterminous in meaning … They are … ordinary English words”. said (at 306B-D):
“The issue is not whether the restriction contained in the first rule is justifiable but how the restriction should be construed having regard to its blanket or discriminative effect in relation to a political body. In view of this the ambiguous words ‘wholly or mainly’ should be construed restrictively. By that I mean they should be construed in a way in which limits the application of the restriction to bodies whose objects are substantially or primarily political. This corresponds with the Shorter Oxford English Dictionary's meaning of ‘mainly’ as being ‘for the most part, chiefly or principally.’ Certainly a body to fall within the provision must be at least midway between the two percentages I have identified, ie more than 75 per cent. This approach to the interpretation of a provision which impedes freedom of communication corresponds with the general approach of the courts of this country, the European Court of Human Rights and many Commonwealth courts in this area … ”
This is a decision on a phrase found in a wholly different context, which, in the view of Lord Woolf and Brooke LJ, required to be construed restrictively. I do not find it of assistance here. “Mainly” here just means “mainly”. In this context, at least, it is just an ordinary English word.[99]The fourth reason is said to be that the New Leases allow multiple occupation and so are not leases for a single residence. To the extent that this submission is based on subletting for holiday purposes, I have already dealt with it. To the extent that it is based on the possibility of occupation of multiple chalets or huts, this is the subject of the next submission, and will be dealt with there.[100]The fifth reason is said to be that the New Leases allow more than one building on each plot, and so allow multiple occupation, which is not a letting ‘wholly or mainly as a single private residence’ within section 19(1A). The first point is that the Leases are leases of the Plot and whatever chalet or hut was already built upon it: see Recital (1) and clause 1. The second is that no further chalet or hut can lawfully be built on the Plot without the consent of the landlord, not to be unreasonably withheld: see clause 3.3(a), set out earlier. The third is that the tenant cannot underlet, share the use of or part with possession of any part of the Chalet Site, except in compliance with certain conditions: clause 3.9.7. Fourthly, unless and until the tenant asks for consent, and is unreasonably refused, the tenant cannot lawfully do these things: see Barrow v Isaacs & Son [1891] 1 QB 417, CA. But the question whether the lease is one of a single private residence must be asked and answered at the time of the grant. The fact that other things may subsequently happen with the consent of the landlord does not mean that the lease is other than what it is at the time you are considering it.[101]The sixth reason is said to be that the New Leases allow buildings to be used for business activities (holiday lets) for 45% of each year and so are not “wholly or mainly” let as a single private residence. I have dealt with this already, in my response to the third reason set out above. In my judgment, even if that were true, it would not prevent the Leases from being “mainly let as a single private residence”.[102]The seventh reason is that the New Leases forbid continuous occupation throughout the year (because there is one month each year when there can be no occupation), and so do not let the plots as a residence. In my judgment, the fact that there is one month in the year when there can be no occupation for any purpose does not prevent the Leases from being “mainly let as a single private residence”. There are eleven months in the year when they can be so occupied.[103]On the other side, the claimants say that there are three reasons why the New Leases are residential leases within section 19(1E). The first is that a “residential” lease can be contrasted with a “business” lease. But these Leases are not “business” leases. I am not impressed by this. The matter is binary, but not along this simple faultline. If Parliament had wished to define a residential lease for this purpose as “any lease which is not a business lease”, it would have said so. Instead, the question is whether the more complex definition in section 19(1E) is satisfied or not.[104]The second reason is said to be that the exclusion is intended to protect residential tenants, on the basis that they are likely to be in a weaker position than business tenants, and tenants of holiday homes are within that weaker position. The claimants cite the decision in Phillips v Francis [2010] L&TR 28. The substantive case concerned leases of holiday homes, and in particular the service charge provisions of the Landlord and Tenant Act 1985, as amended. But the preliminary issue decided in that case was the application of those provisions to those leases. Section 18 defines service charge as “an amount payable by a tenant of a [dwelling] as part of or in addition to the rent … ” The question was whether the premises let fell within the definition of “dwelling” in section 38 of the 1985 Act. That definition reads:
“‘dwelling’ means a building or part of a building occupied or intended to be occupied as a separate dwelling together with any yard, garden, outhouses and appurtenances belonging to it or usually enjoyed with it …”
[105]HHJ Griggs (sitting as a

judge of the High Court) said:

“25. … The definition does not confine the use of the word to a principal home. In common parlance one regularly talks about a ‘holiday home’. There seems to be absolutely no reason why someone cannot have two or more homes. The legislative history may well be interesting but the 1987 Act does not purport to be a ‘consolidation statute’. If it had been, then of course the original meaning would have been carried over into the new consolidated legislation. Parliament has chosen to definition of ‘dwelling’ in the Landlord and Tenant Act 1985 and has not adopted that from the Housing Act: the Landlord and Tenant Act definition is specifically not limited to defining ‘dwelling’ as a main home. Following the guidance of the House of Lords in Uratemp Ventures Ltd v Collins [2001] UKHL 43; [2002] 1 A.C. 301 which makes it clear that the meaning to be attached to the word ‘dwelling’ is very much context specific. I find that the word is not limited to use of a main home as a private residence. 26. It may well be, as Mr Virgo pointed out, that the exclusion of holiday lettings from landlord and tenant legislative protection is not in any sense novel: see s.9 of the Rent Act 1977 and s.1(2) and Sch.1 para.9 of the Housing Act 1988. Plainly it would be inappropriate for there to be security of tenure for someone taking a lease of holiday accommodation. But in my judgment that does not undermine another principle about which Parliament has been concerned namely that unscrupulous landlords should not be able to exploit tenants who are required to contribute to the management costs of an estate … ”
[106]I accept that the judge there took into account the fact that tenant protection is not necessarily confined to security of tenure, but may include (for example) protection from unreasonable charges. Nevertheless, the judge also recognised that every legislative provision has to be construed in its own context. There the judge was construing “dwelling” for the purposes of the service charge provisions of the 1985 Act. It does not follow that the same approach must be taken in dealing with premiums as a condition of consent to alienation. Whilst I bear this authority in mind, I consider that it does not take me very far. It does not, for instance, support the proposition that, wherever you find a tenant who has a weaker bargaining position than the landlord, you should construe the protective legislation so as to include such a tenant. Moreover, the minor premise of the syllogism, that a tenant taking a lease of a holiday home must be in a weaker position, seems questionable to me. Ex hypothesi, the tenant already has a main home, and what he or she is spending is “spare” money. There is no necessity to spend the money at all.[107]The third reason is that, on a close textual analysis of the definition, the New Leases fall within it:
“a lease by which a building or part of a building is let wholly or mainly as a single private residence … ”
First, I agree that the chalets and huts are “buildings”, and that they are let. I also accept, secondly, that in the present case the chalet or plot on each plot was let as a single household unit. Third, such chalet or hut was let mainly as a private residence. The claimants refer to C & G Homes Ltd v Secretary of State for Health [1991] Ch 365 (“care in the community” lettings), and Nemcova v Fairfield Rents Ltd [2017] 1 P & CR 4 (AirBnB lettings). These cases show that a lease to A, who covenants to occupy the demised premises as a private residence, may be breached by A’s allowing persons not part of A’s family or household to occupy the building or a part of the building for stays, long or short.[108]The former case concerned former hospital patients being cared for in the community. Nourse LJ (at 385F) said:
“I would say that if a house cannot fairly be described as someone's private dwelling house, it cannot be said to be being used as such. I therefore ask myself the question which was asked by James LJ in German v Chapman, 7 Ch D 271: whose private dwelling house can it be said to be? It is not the Secretary of State's. And I am unable to say that it is the residents'.”
[109]In Nemcova, which concerned short term holiday lettings, HHJ Stuart Bridge said:
“49. The term ‘private residence’ is a composite term. It may be contended that a room in a hotel is not a ‘private residence’, but if a guest stays there enjoying the facilities for months or years a strong argument could be made that the room has become a private residence of the guest for the time being. For myself, I find it difficult to think of circumstances in which an individual’s ‘residence’ would not be that person’s ‘private residence’ … [ … ] 53. I have reached the view, consistent with the decision of the FtT, that the duration of the occupier’s occupation is material. It does seem to me that in order for a property to be used as the occupier’s private residence, there must be a degree of permanence going beyond being there for a weekend or a few nights in the week. In my judgment, I do not consider that where a person occupies for a matter of days and then leaves it can be said that during the period of occupation he or she is using the property as his or her private residence. The problem in such circumstances is that the occupation is transient, so transient that the occupier would not consider the property he or she is staying in as being his or her private residence even for the time being.”
[110]I do not think that either of these decisions helps me to any significant extent. I see no reason why a property otherwise let to a person mainly as a single private residence, but with express consent to sublet to others during a limited part of any year of the term (not exceeding 5/11) for short-term holiday occupation not exceeding three weeks at a time, should thereby cease to be so let. In the present case, I am satisfied that the New Leases were in fact and law residential leases within section 19(1E) of the 1927 Act. It therefore follows that section 19(1A) does not apply to the present case, and that the defendants cannot rely on the provisions of the Leases in clause 3.9.4 to show that the premium provisions did not constitute an unreasonable refusal of consent to alienation. The third sub-issue[111]I therefore turn to the third sub-issue, which is whether the premium provisions otherwise constituted an unreasonable refusal of consent to alienation. As I have already said, it is the claimants who assert this, and it is they who must prove it. There was little evidence, and even less argument, on this point. They relied, as I have already said, on the statements in cases such as International Drilling Fluids Ltd v Louisville Investments (Uxbridge) Ltd, where Balcombe LJ said (inter alia), that “a landlord is not entitled to refuse his consent to an assignment on grounds which have nothing whatever to do with the relationship of landlord and tenant in regard to the subject matter of the lease”. But this was not said in the context of a local authority seeking to perform its statutory duty. The landlord in that case was a private company.[112]Here it is necessary to consider, not only the special position of a local authority, but also the history of the negotiations between the parties before the New Leases were entered into. I summarised this history earlier in this judgment. It is clear that the defendants were concerned to make sure that they complied with their statutory obligation as local authorities to ensure that, if they disposed of an asset, they did so for the best possible consideration that could reasonably be obtained. They took professional advice on this from a well-known and reputable firm of surveyors. They then adopted the surveyors’ recommendation to offer terms that did not require a premium on grant of the lease, but did require a payment of part of the price paid for a future assignment of the lease. Those terms were accepted by the tenants, who were also professionally advised. As I have already said, no evidence was adduced as to the circumstances in which any of the New Leases was granted to individual tenants, nor as to circumstances which might make it unreasonable for the defendants to seek payment of a premium upon assignment. Conclusion[113]I am satisfied first of all that section 144 applied in principle to the New Leases, but has been disapplied from them by the provision in clause 3.9.4. So the provision that would be implied in the New Leases by virtue of section 144 is not so implied. Secondly, I hold that section 19 of the 1927 Act also applies in principle to the premium provisions of the New Leases. Thirdly, I hold that the New Leases are “residential leases” as defined by section 19(1E) of the 1927 Act. It follows that the defendants cannot rely on section 19(1A) to show that withholding consent to assignment except on compliance with the premium provisions is not unreasonable.[114]On the other hand, that does not conclude the matter as to whether, if in the future they gave consent to an assignment conditionally on payment of a premium in accordance with clause 3.9.4, that would be an unreasonable withholding of consent within section 19(1). But I cannot decide that question in relation to any of the New Leases at this stage. The circumstances in which such consent would be sought have not arisen, indeed may never arise, and I have no evidence about them.[115]Accordingly, the claim for declarations(i) that clause 3.9.4 of the New Leases is void, and(ii) that the defendant landlords are not entitled to the payment of premiums on the assignment of leases which they have granted to the claimants is dismissed. I should be grateful for a draft minute of order to give effect to this judgment.