Hays Business Services Ltd v Raley (Valuation Officer): 1986

A warehouse was used for the storage of archival materials including documents, films and audio-magnetic tapes. For some items of a sensitive nature, there had been installed specialist items of plant, including heating plant, humidifiers, and fire-protection equipment which utilised Halon gas so as to extinguish fires without damaging the stored items. The Solicitor for the Inland Revenue, for the Valuation Officer, had conceded that the specialist heating and humidification equipment were non-rateable.
Held: The tribunal agreed in respect of the fire protection plant, which was not rateable because it was ‘on the hereditament primarily to protect the material that is stored there’. It added: ‘Even if it were to be found that this could only be done by the protection of the building and therefore that that was the main use of the equipment, it would nevertheless not be included within the schedule because it was there expressly for the purpose of the trade process being carried on.’


Emlyn Jones FRICS


[1986] 1 EGLR 226 (LT)


England and Wales

Cited by:

CitedIceland Foods Ltd v Berry (Valuation Officer) SC 7-Mar-2018
Air System plant excluded from Rating value
The court was asked whether the services provided by a specialised air handling system, used in connection with refrigerated merchandise in the appellant’s retail store, are ‘manufacturing operations or trade processes’ for rating purposes.
Lists of cited by and citing cases may be incomplete.


Updated: 16 May 2022; Ref: scu.605777