Secretary of State for Communities and Local Government v Redhill Aerodrome Ltd [2014] EWCA Civ 1386
Redhill Aerodrome is a leading Court of Appeal authority on the Green Belt very special circumstances balance.
It confirms that the expression “any other harm” is not limited to harm to the Green Belt. Other planning harm caused by an inappropriate development must also be weighed against the considerations relied upon to establish very special circumstances.
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- Neutral citation
- [2014] EWCA Civ 1386
- Court
- Court of Appeal (Civil Division)
- Judgment date
- 24th October 2014
- Judge
- Sullivan LJ, Tomlinson LJ and Lewison LJ
- Case number
- C1/2014/2773, 2756 and 2874
What did “any other harm” mean?
The proposal was for a hard runway and associated works at Redhill Aerodrome in the Metropolitan Green Belt. It was inappropriate development.
The central legal question was whether “any other harm” in the national Green Belt policy meant only additional harm to the Green Belt, or whether it included other planning harms such as landscape impact, visual impact, noise and traffic.
The Court of Appeal held that the words carry their ordinary meaning. They include any other planning harm caused by the development.
Harm does not disappear because it falls below a separate refusal threshold
The court rejected the argument that a harm should be ignored in the Green Belt balance merely because it would not, taken alone, justify refusal under another part of national policy.
For example, a transport impact may be less than the policy threshold for refusal on transport grounds but can still be a material adverse effect. It may therefore still weigh against an inappropriate Green Belt development when the decision-maker asks whether very special circumstances exist.
The balance must be even-handed
The Court regarded it as illogical to count non-Green Belt benefits on one side of the balance while excluding non-Green Belt harms from the other. If economic, employment or transport benefits can support very special circumstances, planning harms outside the narrow Green Belt purposes must also be capable of weighing against the proposal.
Why Redhill Aerodrome matters
The case remains a useful warning against artificially narrowing the Green Belt balancing exercise. The decision-maker should identify the harm arising from inappropriateness and any other material planning harm, give the Green Belt harm the weight required by current policy, and then ask whether the considerations in favour clearly outweigh the harm so as to amount to very special circumstances.
The paragraph numbers considered in Redhill relate to the 2012 NPPF. The principle should therefore be applied through the wording of the current national Green Belt policy rather than by copying historic paragraph numbers.
Read the full Redhill Aerodrome judgment
Planning Geek holds the approved Court of Appeal judgment in the protected case law library. Gold Members can open the PDF below.
Redhill Aerodrome Case Law Page Updated: 11th September 2026