The court considered what premises were protected under the Rent Acts. A bungalow had been let with a campsite.
Held: The dominant purpose was for business use, and the tenancy of the bungalow was not protected.
Denning LJ: ‘The guiding light through the darkness of the Rent Acts is to remember that they confer personal security on a tenant in respect of his home. The Acts apply to dwelling-houses, not to business premises. This is shown by the opening words of section 12(2) of the Act of 1920 which applied the Acts to houses ‘let as a separate dwelling’ and section 3 of the Act of 1939 which applies the Acts to ‘dwelling-houses’. Those are the governing words. The remaining words of those sections are concerned with marginal cases, such as a house where the front rooms are used as a shop; and a house let with a field, and so on.’
Somervell LJ: ‘There was a time when business premises were included, but it is common ground that it is now dealing with dwelling-houses.’
Denning LJ, Romer LJ, Somervell LJ
[1952] 2 QB 29
England and Wales
Housing
Updated: 10 December 2021; Ref: scu.245804