Terence Charles Measor v Secretary of State for the Environment, Transport and the Regions and Tunbridge Wells Borough Council [1998] 4 PLR 93
The point in plain English: A caravan is not automatically a building for planning purposes merely because caravan legislation describes it as a structure. Whether it is a building remains a question of fact and degree, with permanence, physical attachment, size and composition among the important factors.
What the High Court decided
The case concerned residential and touring caravans at the Post Boys Motel. Mr Measor argued that the residential caravans were buildings and therefore fell within the former four-year enforcement period for a change of use of a building to a single dwellinghouse.
The High Court rejected that argument on the facts. The Inspector had been entitled to find that the caravans lacked the permanence and attachment necessary to amount to buildings. Their description as structures under caravan legislation did not determine the separate planning-law question.
A second challenge alleging bias or procedural unfairness because the Inspector knew the A21 and remembered the site also failed. The evidence did not establish a real danger that independent knowledge had influenced the decision.
Important current-law warning
The enforcement time-limit discussion is historic. England’s general enforcement time-limit regime changed from 25th April 2024. The case remains useful principally for the building-versus-caravan analysis and the fact-and-degree approach.
See Planning Geek’s current guide to enforcement time limits.
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