R (Save Greater Manchester Green Belt Ltd) v Secretary of State for Housing, Communities and Local Government & Ors [2025] EWHC 2742 (Admin)
Save Greater Manchester Green Belt is a Planning Court judgment on the meaning of exceptional circumstances when a Local Plan adds land to the Green Belt.
The challenge concerned the Greater Manchester joint development plan, Places for Everyone 2022-2039. Mrs Justice Lang dismissed the claim and held that the examining Inspectors had not unlawfully narrowed the circumstances capable of justifying additions to the Green Belt.
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- Neutral citation
- [2025] EWHC 2742 (Admin)
- Court
- High Court of Justice, King's Bench Division, Planning Court
- Judgment date
- 24th October 2025
- Judge
- Mrs Justice Lang DBE
- Case number
- AC-2025-LON-001100
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The plan both removed and added Green Belt land
The Greater Manchester authorities prepared a joint plan which proposed substantial releases from the Green Belt for development. Earlier versions also proposed a number of additions to the Green Belt.
During the examination the Combined Authority revised its approach. The examining Inspectors ultimately supported some proposed additions and rejected others.
The claimant argued that the Inspectors had applied an unlawfully restrictive legal test to the question of when land could be added.
Exceptional circumstances apply to additions as well as removals
The court accepted that altering an established Green Belt boundary in either direction is a serious step.
The same general national-policy requirement for exceptional circumstances applies when land is added to the Green Belt as when it is removed. Adding land can itself have significant consequences for landowners and future development.
Exceptional circumstances is deliberately broad
Mrs Justice Lang rejected the suggestion that the phrase has a narrow legal definition.
It is a broad planning-policy concept which calls for planning judgment. The circumstances capable of being exceptional cannot be exhaustively defined in advance.
The well-known observations in Copas about assumptions behind an existing Green Belt boundary being falsified were not a universal rule requiring that test to be met in every case.
The Inspectors did not confine themselves to a rigid two-part test
The claimant said that the Inspectors had allowed additions only where there had been a fundamental change of circumstances or an anomalous boundary needing correction.
The judgment found otherwise. The Inspectors also considered other site-specific circumstances where they judged that an issue required resolution through the plan.
They did not simply accept the Combined Authority’s position either. They reached different conclusions on individual sites, demonstrating an independent planning judgment.
Using criteria to structure the judgment was lawful
A decision-maker may adopt sensible criteria to help assess whether exceptional circumstances exist. That does not convert the policy into an inflexible legal code, provided the decision-maker remains open to the circumstances of the individual case.
The court therefore rejected the argument that the Inspectors had unlawfully constrained themselves.
The case concerned the 2021 NPPF
The examination and challenge arose under the national Green Belt policy then in force, including the 2021 NPPF.
The legal point about the breadth of planning judgment remains useful, but current plan-making should be checked against the August 2026 Green Belt policy and the current plan-making regime.
For the wider examination process, see our Local Plan examination guide.
Read the full judgment
The approved Planning Court judgment is held in the Planning Geek case law library. Gold Members can open the protected PDF below.
Save Greater Manchester Green Belt Case Law Page Updated: 9th September 2026