Hobbs (Quarries) Ltd v Somerset County Council (1975) 30 P&CR 286
Hobbs (Quarries) is an important planning-compensation case on the scope of loss which may be directly attributable to the revocation or modification of a planning permission.
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- Neutral citation
- (1975) 30 P&CR 286; [1975] RVR 219; [1975] 1 EGLR 189
- Court
- Lands Tribunal
Anticipated profits can in principle be compensatable
Later authorities describe Hobbs as establishing that statutory planning compensation is not necessarily confined to the reduction in the capital value of land. Loss directly attributable to the statutory planning action can include anticipated business profits, provided the necessary tests of causation and remoteness are satisfied.
The business did not have to be already trading
The claimant had purchased an existing quarry for the purpose of obtaining a supply contract. Later tribunals have explained that the loss succeeded even though the relevant business operation had not yet begun, because the intended commercial activity was sufficiently concrete and the statutory notice deprived the claimant of the opportunity for which the quarry had been acquired.
This does not mean that every hoped-for future business or development profit is compensatable. Later cases distinguish Hobbs where the alleged business remained speculative or had not progressed far enough to establish the necessary causal connection.
Direct attribution and double recovery remain separate questions
Hobbs is authority for the breadth of losses that may fall within planning-compensation provisions, but the claimant must still prove that the loss is directly attributable to the relevant planning action. Ordinary compensation principles, including causation, remoteness, mitigation and the rule against double recovery, continue to apply.
Source limitation
Planning Geek does not currently hold the original Lands Tribunal report. The case is discussed in later Lands Chamber decisions and official compensation material, which confirm its treatment of anticipated profits.
The Planning Inspectorate has also referred to Hobbs when explaining that wording equivalent to section 107(1)(b) can include loss of profits reasonably expected to have been earned from the affected land.
Hobbs (Quarries) Case Law Page Updated: 11th September 2026