Wyre Forest District Council v Secretary of State for the Environment and Allen’s Caravans (Estates) Ltd [1990] 2 AC 357
The point in plain English: Where planning legislation gives “caravan” a statutory definition, that definition will normally govern the same word in a planning permission unless the context clearly indicates otherwise. A chalet does not have to look like an ordinary touring caravan or have wheels to fall within the statutory definition.
What the House of Lords decided
The case concerned the Sladd Lane caravan site at Wolverley. Planning permission granted in 1961 authorised the continuation of the caravan-site use and referred to the siting of 205 caravans. In 1985 a chalet was placed on the site. The structure did not fall within the everyday idea of a caravan, but it was capable of being moved and fell within the statutory definition in section 29(1) of the Caravan Sites and Control of Development Act 1960.
Wyre Forest District Council served enforcement notices on the basis that the chalet was a fresh structure outside the permission. The Secretary of State allowed the site owner’s appeal, but the Court of Appeal subsequently found for the Council. The House of Lords reversed that decision.
Lord Lowry explained that where Parliament defines a term, the defined meaning will normally govern things proposed, authorised or done under or by reference to that legislation unless the context shows otherwise. The planning permission therefore used “caravan” in its statutory sense. The chalet was within that definition and the enforcement notices could not stand.
Why the case still matters
Wyre Forest is important whenever the planning question turns on what a “caravan” is. Appearance, wheels and industry terminology are not decisive. The statutory definition must be considered first.
That is particularly relevant to modern mobile homes and specialist production units. A large unit can be a caravan even though it looks more like a building or chalet, provided it meets the statutory requirements. Conversely, a unit described commercially as a caravan or trailer does not qualify merely because of its name.
The case should be read alongside Carter on the mobility requirement and Planning Geek’s existing Measor entry on the separate question of when a caravan may also amount to a building for planning purposes.
Source note
This is currently a summary-only entry. Planning Geek checked the House of Lords decision and reported citations through an open-reading copy of the speeches. A clean official or otherwise freely rehostable transcript has not yet been secured for the local document library.
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