A Class Q appeal at Reynards Rest in Hampshire has failed even though the Inspector accepted that the building itself really had been used for agriculture.
The problem was a different part of the permitted-development test. The evidence did not adequately establish the geographical extent of the former established agricultural unit or demonstrate how the appeal building formed part of that unit.
The decision is a useful reminder that proving agricultural use of a building and proving membership of an established agricultural unit are related questions, but they are not the same question.
Why Reynards Rest failed the agricultural unit test
Inspector E Everitt dismissed appeal 6011719 on 7th September 2026. The site is Reynards Rest, Willis Lane, Four Marks, Alton, within East Hampshire District Council. The Inspector’s decision spells the property name ‘Raynards Rest’, but the Land Registry title uses ‘Reynards Rest’.
The prior-approval proposal sought to convert the building to a dwelling under Class Q of Part 3 of the GPDO.
On one important factual issue, the appellant succeeded. The Inspector accepted the evidence that the building had formerly been used for agricultural purposes.
The material included statutory declarations relating to an earlier calf-rearing enterprise and other evidence about the history of agricultural activity. The Inspector was satisfied that the building had genuinely had an agricultural use; this was not a case where the agricultural history of the building itself was rejected.
Agricultural use did not prove the agricultural unit
Class Q does not ask only whether a building was used for agriculture. The right also depends on the building being, or formerly having been, part of an established agricultural unit.
That is where the evidence failed.
The Inspector found that there was no clear definition of the location or geographical extent of the former agricultural unit relied upon. It was not adequately shown which surrounding land formed part of that unit, or how the appeal site and building related to it.
This mattered because the surrounding agricultural land had changed hands over time. Evidence that a building once contained agricultural activity did not, on its own, identify the wider unit of agricultural land of which it was said to form part.
Our separate guide explains what an agricultural unit means in planning terms. An agricultural unit can comprise more than one parcel and ownership is not automatically decisive, but the claimed unit still has to be identified and evidenced.
What evidence was missing?
The decision should not be turned into a rigid evidential checklist. The Inspector did not say there is one prescribed bundle of documents that every Class Q applicant must produce.
But she did identify the weakness clearly. There was no substantive land-ownership information or agricultural-holding material which filled the gap and established the extent and identity of the former unit.
In other words, the missing evidence was not simply another photograph of the barn or another statement saying it had agricultural use. What was needed was evidence capable of connecting that building to the historic agricultural holding relied upon.
Our analysis: depending on the facts, useful evidence may include historic ownership or occupation material, agricultural holding records, maps or other records that define the land operated together. What matters is not the label on the document but whether it proves the particular unit being relied upon.
Paragraph W puts the evidential burden into focus
The appeal also contains a useful reminder about paragraph W, the prior-approval procedure applying to Part 3 rights such as Class Q.
Paragraph W allows a local planning authority to refuse prior approval where the proposed development does not comply with the applicable conditions, limitations or restrictions, or where insufficient information has been provided to establish that it does.
That became decisive here. The Inspector was not satisfied, on the material submitted, that the building met the relevant Class Q requirement concerning the established agricultural unit.
The appeal therefore failed because the appellant had not provided enough evidence to establish that the development fell within the permitted-development right.
This fits the wider principle explained in our prior approval guide: a prior-approval application is not simply an invitation for the council to assume that the underlying permitted-development right exists.
The distinction is easy to miss
There are really two propositions in this appeal:
- The building had genuinely been used for agriculture
- The evidence did not adequately prove the established agricultural unit of which the building was said to form part
Those findings are not contradictory. The first concerns the use of the building. The second concerns the identity and history of the wider agricultural unit required by Class Q.
That distinction can be particularly important with older barns and former smallholdings where land has been divided, sold or reorganised over the years. The more complicated the historic holding, the more important it becomes to evidence the unit rather than relying on the agricultural appearance or use history of the building alone.
The Planning Geek takeaway
Proving that a building was agriculturally used does not necessarily prove that it formed part of an established agricultural unit.
For a Class Q application, evidence should be directed to each part of the legal test. Where the right depends on a historic agricultural unit, the application needs enough material to identify that unit and connect the building to it.
The Inspector did not find that the building’s agricultural history was invented or insufficient. The appeal failed because a separate element of the Class Q test had not been established on the evidence.
You can read the full Class Q appeal decision 6011719 hosted by Planning Geek.
Sources: appeal decision 6011719 and the current Class Q and paragraph W provisions of Schedule 2, Part 3 of the General Permitted Development Order.
Created: 8th September 2026
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