Cardiff Rating Authority and Cardiff Assessment Committee v Guest Keen Baldwin’s Iron and Steel Company Ltd [1949] 1 KB 385
Cardiff Rating was a rating case rather than a planning case, but it became highly influential in planning law because later courts adopted its approach to deciding whether an object has the character of a building or structure.
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- Neutral citation
- [1949] 1 KB 385; [1949] 1 All ER 27
- Court
- Court of Appeal
- Judge
- Denning LJ and Jenkins J are expressly quoted in later authorities; the full constitution has not been independently verified
The three familiar building factors
The case is repeatedly cited for the relevance of three broad factors when deciding whether an object is a structure or building: size, permanence and physical attachment.
Denning LJ also described a structure as something substantial, built up from component parts and intended to remain on a site with a sufficient degree of permanence.
Why a rating case matters in planning
The planning significance comes from later cases adopting the Cardiff approach. In Skerritts of Nottingham Ltd v Secretary of State [2000] EWCA Civ 5569, the Court of Appeal considered the test appropriate when deciding whether a large seasonal marquee was a building for planning purposes.
Skerritts also makes clear that the factors are not rigid statutory requirements. Whether something has sufficient size, permanence and attachment remains a question of fact and degree in its planning context.
Source limitation
Planning Geek does not currently hold the original 1949 law report. This summary is therefore checked against later judgments which quote and apply Cardiff Rating, particularly Skerritts of Nottingham Ltd v Secretary of State [2000] EWCA Civ 5569.
The original case should be consulted from an authorised report where the precise ratio or wording matters.
Cardiff Rating Case Law Page Updated: 11th September 2026