John Keen v Secretary of State for the Environment and Aylesbury Vale District Council (1996) 71 P&CR 543
The point in plain English: If a genuine need for a rural worker to live at or very close to an agricultural holding has been accepted, an existing house is not automatically suitable and available simply because the farmer owns and occupies it.
What the High Court decided
The Inspector accepted that the expanding livestock enterprise needed a full-time stockman living on or very close to the farm. He nevertheless refused a new dwelling on the basis that the farmer and his wife could move out of, or share, their substantial four-bedroom family home with the worker.
The High Court quashed the decision. The Inspector had not properly examined whether that house, or part of it, was genuinely available and suitable for the worker and any family. Mere physical existence of accommodation was not enough.
Why Keen still matters
The case applied the former PPG7 policy and should not be treated as the wording of current national policy. Its practical lesson remains useful: once existing accommodation is relied upon to answer an identified rural-worker need, its real availability and suitability need evidence and reasoning rather than assumption.
See Planning Geek’s current guide to rural workers’ dwellings.
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