R (on the application of Ribble Valley Borough Council) v Secretary of State for Housing, Communities and Local Government and Majid Hussain [2025] EWHC 2363 (Admin)

Ribble Valley is an important Planning Court judgment on previously developed land in the Green Belt. It applies the earlier Lee Valley case to a large equestrian site containing buildings, a ménage, tracks and paddocks. The court held that the Inspector could not simply treat the entire 5.68 hectare site as previously developed land without analysing which parts actually met the NPPF definition.

Neutral citation

[2025] EWHC 2363 (Admin)

Court

High Court of Justice, King's Bench Division, Planning Court

Judgment date

25th September 2025

Judge

Karen Ridge, sitting as a Deputy High Court Judge

Case number

AC-2024-MAN-000331

What Ribble Valley decided

The appeal concerned a proposal for a single private dwelling on land at Further Lane, Mellor, near Blackburn. The 5.68 hectare Green Belt site was in commercial equestrian use and contained paddocks, a ménage, buildings, stables, parking and associated development.

Ribble Valley Borough Council refused permission. At appeal, the Inspector concluded that the whole site was previously developed land and that the proposal therefore fell within the Green Belt exception then found in paragraph 154(g) of the NPPF because it would not have a greater impact on openness.

The council challenged that decision. The Planning Court quashed the permission.

The Inspector had to apply the Lee Valley mixed-site approach

The court relied on Lee Valley Regional Park Authority v Broxbourne Borough Council. That case makes clear that some previously developed land within a site does not automatically make the whole site previously developed land.

At one extreme, a site might be overwhelmingly developed with only a trivial undeveloped corner. At the other, a small developed corner will plainly not turn a largely open site into PDL.

Between those extremes are mixed sites where the relative developed and undeveloped parts matter. Ribble Valley was one of those cases.

The 5.68 hectare site was not uniformly developed

The evidence showed buildings and a ménage concentrated mainly in the western portion, wooden stables in the north-eastern corner and large areas of paddock between them.

The Inspector himself described the development as piecemeal and recognised that the proposed house would be at the opposite end of the site from much of the existing equestrian development.

Those characteristics called for an assessment of the constituent parts. A single sentence saying that the site was PDL was not enough.

An equestrian use does not itself make land previously developed

One of the Inspector’s reasons for finding the site to be PDL was its equestrian use and the distribution of equestrian equipment across it.

The court held that the use itself was an irrelevant consideration for this purpose. The NPPF definition is concerned with physical development such as permanent structures, their curtilage and associated fixed surface infrastructure.

A paddock does not become previously developed land merely because it forms part of an equestrian business or because movable equestrian equipment is placed across it.

The reasons were too thin for such an important policy conclusion

Neither party had gone into the hearing with a positive written case that the whole site was PDL. The issue emerged during the hearing.

That made the Inspector’s reasoning particularly important. The conclusion that the whole site was PDL determined whether the house was inappropriate development and whether the Green Belt very special circumstances exercise was needed.

The court held that the one-sentence explanation did not allow the council to understand how the NPPF definition had been applied to this mixed site.

The conclusion was also irrational

The court went beyond inadequate reasons. Given the size of the site, the extensive paddocks and the concentration of development in particular areas, it was irrational to ignore the large undeveloped areas and simply conclude that the entire site was previously developed land.

The court held that, with a proper analysis, parts of the proposal would have involved inappropriate development in the Green Belt. That harm would then have required substantial weight in the planning balance.

The openness finding did not cure the PDL error

The Inspector had separately found that the proposed house would improve visual and spatial openness despite an increase in built volume.

That did not make the error harmless. The first question was whether the land on which the exception was being relied upon was actually previously developed land. If development was proposed on non-PDL parts of the site, the Green Belt policy consequences for those parts still had to be assessed.

The court could not say the appeal would necessarily have been allowed if the correct approach had been taken.

The current NPPF should still be checked

Ribble Valley concerned the Green Belt policy wording and paragraph numbering then in force, including paragraph 154(g). National policy has since changed, including the introduction and development of grey belt policy.

The judgment nevertheless remains highly useful when applying the definition of previously developed land to a mixed site. It is the physical character and development of the land that matters, and a decision-maker must explain how substantial undeveloped areas have been treated.

Read the full Ribble Valley judgment

The approved Planning Court judgment is held in the Planning Geek case law library. Gold Members can open the protected PDF below.

Related Planning Geek guidance

See our guides to grey belt, Green Belt, greenfield and brownfield land and previously developed land. Ribble Valley is best read alongside the Planning Geek Case Law page for Lee Valley.

Ribble Valley Case Law Page Updated: 9th September 2026