Adverse Possession Pack Komilla Chadha

7/30/2019 Adverse Possession Pack Komilla Chadha

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Adverse PossessionWhat is adverse possession1. Adverse possession can be explained as the process of possession that changes the ownership of

land from the paper owner to the possessor.

2. It arises out of the s.15 (1) Limitation Act 1980.

3. What is needed to establish adverse possession?

Factual Possession - where there is strong physical evidence that somebody is in possession ofthe land e.g. that may include fencing and locking the land.

In Powell v McFarlane, Slade J provides an in-depth explanation on what factualpossession means.

This explanation was accepted by the House of Lords in Pye v Graham, here thejudges reinforced the need for appropriate degree of physical control to count asfactual possession.

Contrast this to Tecblid v Chamberlin Ltd where children playing on the land andtethering of ponies was not sufficient.

Important to ask is the land being possessed or merely used for profits as in Powellv McFarlane.

Animus Possidendi - an intention to possess . How do we prove this?

The actions by which the owner has made the intention clear, Buckinghamshire CC vMorgan 1990 and Powell v McFarlane 1977

Affirmation that outward conduct is demonstration of intent, Prudential AssuranceCo Ltd v Waterloo Real Estate Inc [1999]

Land must be used for the squatters advantage and locking/blocking access to land isan indefinite evidence for the intention to possess and factual possess,Buckinghamshire CC v Morgan 1990, Pye v Graham 2003 and Powell v McFarlane1977

Key is intention to possess not acquire, in Lodge v Wakefield 1995, the mistaken beliefthat you own the land combined with factual possession was sufficient to prove thatadverse possession had taken place.

Furthermore, in Pye v Graham it is made clear that if the possessor offers to pay rent oragrees (so long as he actually hasnt given it), is fine for adverse possession because it isan intention to possess not acquire.

Often, intention is intertwined with factual possession but in Pye v Graham, thedistinction is made clear between the two. An example is provided; X is in occupationof a locked house which he has agreed to look after for a friend, whilst friend is away.He may have factual possession but the intention which is very much linked to thethird requirement is missing and thus cannot be adverse possession.

(Possession must be adverse as with consent that would not be adverse possession)

SUBJECT: LAW OF PROPERTY KOMILLA CHADHA

PAGE 1 OF 12 REVISION PACK


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4. If however, the paper owner forced you offthe land, or decides to enter into a licensingagreement then adverse possession is no longer possible. This is because in the first case thesquatter fails to assert a better claim and in the second the possession will no longer be adverse.

5. It was actually the case of Leigh v Jack which was held in Beaulane Properties Ltd v Palmerthat the old doctrine stated the use must be different to the paper owners. This was of courserejected in Pye v Graham where the notion of an implied license was too.

6. The justification for adverse possession lied in the Lockean principle that if you mix your labourwith resources then the end product should become yours.

7. It is important to note that, even derivative title at some point came from an original sourcewhich was possession so adverse possessors arent some distasteful sect of society we shouldshun, so some argue. Lord Brown-Wilkinson, makes this point clear in Pye v Graham 2002. Hesays that much confusion would be avoided if we didnt refer to adverse possessors as those whobehave badly - it is just possession and the process of possession creating title. It is similar to alicensee where temporary possession is given not future rights.

8. From a Human Rights prospectus it was found that adverse possession does not infringe

human rights in Pye v Graham, as adverse possession was justified control of use of land than adeprivation of possession and was within margin of appreciation. Another point is that underArticle 8 of ECHR sometimes arguments can be made that English law breaches the right torespect for home and family by not allowing adverse possession.

9. In registered land, any rights in the course of being acquired by adverse possession count asoverriding interests which means that any third party purchaser say, is also bound by the rightsof the possessor.

What is the procedure adverse possession?

1. The future rights of an adverse possessor arise out of the Limitation Act 1980 s.15 (1) No actionshall be brought by any person to recover any land after the expiration of twelve years from thedate on which the right of action accrued to him or, if it first accrued to some person throughwhom he claims, to that person.

2. First adverse possession must be established via factual possession and animus possidenti.

3. Then identify if the land is registered or unregistered

4. Then identify is the adverse possession is a case pre-2003 or post 2003

5. If it is pre-2003 and unregistered, after 12 years the land automatically becomes the adversepossessors under s17 of The Limitation Act.

6. If it is pre-2003 and registered, after 12 years, the land is held on trust under s75 LandRegistration Act, an extra three years is required for procedural reasons and after 15 years thepossessory title is changed.

7. If the 12 years end after 2003, the unregistered rules do not change.

8. If the 12 years end after 2003 and the land is registered, after 10 years the adverse possessor canapply to the land registry and the paper owner is given 65 working days to respond. If he doesnot respond, then the land becomes the squatters otherwise the owner is given two years tochuck the squatters out.

9. In September 2012, criminalization of adverse possession in residential areas can into form.

10. Also note that under LRA 2006 Sch 6 para 8(2) no application for adverse possession can bemade where the registered propriatrator is mentally disabled, ill or abroad does not matter.




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Title

1. The degree of interest in something against the world, that someone holds, is referred to astitle.

2. In the English legal system, only relative titles can be found. This means that your title onlydenotes your interests relative to others title, even in the case of a fee simple, the title of theowner is relative to that of the Crown.

3. Title is an important part of adverse possession, this is because adverse possession can be theroot the to title. So it is important to understand the end result from successful adversepossession.

4. We can classify the root of title as derivative or original. Derivative title is a title that derives itsexistence from a preexisting title whereas an original title is one where there exist no prior title.Adverse possession leads to the creation of an original title as titles that derive their existencefrom possession not a prior title are original.

5. In the case of registered land, title is proved by looking at the register (this can also apply toother types of properties like cars and shares). Where unregistered land is concerned,provenance is used to prove a sound a title. This means that you have to prove an unbrokenchain of ownership for the last 15 years. Of course, you can see the problem this broughtespecially with human error and so that is why registration is not only compulsory but is thepreferred method.

6. To prove title is money and chattels is different, however. Titles referring to chattels are provedby who is in possession of the chattel, this is because it would be costly to register everytransition of the chattel. Furthermore, money is also proved by who is in possession of it andthis is again for practicality issues, as you can imagine if every transaction involving money hadto noted in a registered.

7. Nemo dat quad non habet, a latin principle essentially means that one cannot give what theydo not have. So one cannot give a title they do not own. This is important because land tends tohave multiple title holders, all with different interests, this principle ensures that one cannotgive a title that they do not have. Of course, this is different with money as ownership isreflected in possession and so it on the basis of possession that transactions take place.

8. The important case when demonstrating the nemo dat principle is Bruton v QuadrantHousing Trust which shows that the principle was so crucial that courts created a new type ofproperty interest non-proprietary lease




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9. In an unregistered land system, the nemo dat rule governs title. However since the LandRegistration Act 2002, the nemo dat principle has become largely redundant. This is becausethe registered land system moves more towards a system of absolute ownership, which is thatthe registered owner has the best title against anyone else in world regardless of whether it wasby mistake or fraud that they became a registered owner.

10. It is important to note that in the case os registration, this can sometimes lead to unjust resultssuch as mistakes with title that occur due to human error or fraud.

11. English law struggles to deal with the conceptual issues surrounding ownership and that iswhy instead of looking at absolute ownership, we look at relative ownership on the premise ofpossession and title.




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Cases

Here you will a summary of all the cases I have referred to in the study pack.

Buckinghamshire CC V Morgan [1990]

Facts: The claimants bought a property with a plan to build a road on it. The defendant who was a

neighboring landowner, cultivated and treated the councils land as his own and used it as a garden.Some 30 years late the authorities returned to the property with a view to build on it but they werestopped.

Judgement:

The Court of Appeal prevented the authority of building on the land as they stated it had beenadversely possessed. The defendant was not obliged to show he had intended to adversely possessthe property indefinitely as he had showed factual possession by fencing of the land and only havethe exclusive possession to the key which allowed one to enter the land.

Importance:

Previously, the adverse possessor not only had to prove physical possession but that somehow the

possession was adverse and this was done through looking at the intention of the parties. However,in this case the court found it unnecessary to see if intention was present as the factual possessionwas sufficient to prove intention. It is important to note that the fact that the paper owner had afuture intended use for a road did not stop defendant from adversly possessing the land unlike inWalliss Cayton Bay Holiday Camp Ltd v Shell-Mex and BP ltd where the future intended use andthe implied license rationale led to the judgement that adverse possession had not taken place.

Pye JA V Graham [2003]

Facts: The claimants allowed the defendant to use the land under a contract for grazing. Thedocument expressly said that after a certain date the agreement would not be a valid and anothercontract would need to be drawn up for the grazing to continue. After attempts to establish another

contract, the defendants continued to use the land for grazing and after 12 years sough to adverselypossess the land.

Judgement:

The High Courts ruled that the land was adversely possessed under the Land Registration Act2002. The Court of Appeal overturned this decision because they said the grazing existed becauseof the contractual agreement and it did not show possession of the land. The House of Lords,however, returned back to the High Courts decision saying the land was adversely possessed andled to the creation of the Land Registration Act which stated that all adverse possession must nowbe registered.

Importance:It is a great case for demonstrating exactly what is meant by factual possession of the land, which isthat there must be an ability to exclude the paper owner which the defendants could do as theyfenced offparts of the land and retained the keys to those parts. Furthermore, the earmarking ofland for furture use will one in rare circumstance be used to argue against adverse possession.

Powell v McFarlane 1977

Facts: The claimant claimed to have been in adverse possession of some land in surrey since 1956(when he was 14) as he grazed the family cow on that land. The fee simple registered owner thedefendant bought the land in 1952. As a child he persuaded his grandparents to write to thedefendant there is no evidence or a response or that he ever received the letter. Regardless, he begin

using the field. Once the family cow died he used the field to advertise his business and as a car parkfor his business. McFarlane had no idea of this and because of his work postings sent his wife tocheck up on the land. She noticed a sign board and no sign of activity and as the board did no harm




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did not report or question it. Later, she noticed new fencing and realized what was happening andthe claimant responded by saying he had adversely possessed the land.

Judgement:

In deciding whether the claimant has acquired possession, the courts assessed the significance ofwhat he had done to the field. Slade LJ laid a few physical feautures which as indefinately count as

factual possession; cultivation of agricultural land, enclousure, notice to keep intruders off

andlocking or blocking the only means of access. The plaintiffdid not do any of these things but ratherhe gained profits from the plant by grazing his cow and possibly goat. The nature of the actvity is assuch that would not require him or his animal to be there everyday. Furthermore, he himself ownedno land in close promixity or any land at all for that manner. He was deemed not be in possession. Itis largely unimportant the ignorance presented by the paper owner as an adverse possesor seeking totake in land must show at least to some extent his intention which was not done so.

Importance:

It is a great case for demonstrating exactly what is meant by factual possession of the land, Slade LJstresses that factualpossession is necessary for demonstrating animus possendenti.

Prudential Assurance Co Ltd v Waterloo Real Estate Inc 1999

Facts: The claiment appealed a decision that rendered aa party wall to be wholly possessed by theclaiment and so the paper owner. The defendant was already the paper owner of the northern sideand claimed to have adversely possessed the southern side. The claiment argued that the criteria foradverse possession should not be limited to the Powell factual possession and that it should beextended to the knowledge of the paper owner. The defendant argued that he only needed to makehos intention to the world not the paper owner.

Judgement:

Dismissing the appeal, the court argued that conduct was diff

erent to the assertion of rights it wasan outward demonstration of an intention to possess and treat the land as their own which thedefendants had clearly done.

Importance:

Follow on from Powell case.

Parker v British Airways Board 1982

Facts: An air passenger found a gold bracelet in the international executive lounge of an airport.The lounge was leased to the defendants. When the gold bracelet was handed in, the plaintiffrequested that it be returned to him had the true owner not been found.The defendants sold thebracelet for 850 as the true owner was not found and kept the returns. The plaintiffappealed.

Judgement:

The court of appeal said that the air passenger had a better right to the gold bracelet than theoccupiers - British Airways Board, because it was found that the Board did not have a policy ofsearching for lost articles. The plaintiffwas awarded 850 in damages and 50 in interest.

Importance:

The plaintiffin taking the bracelet into his care and control acquired possession which was againsteveryone but the true owner. By handing it in he acted honestly discharging his duties of a finder.The only way the defendants could demonstrate an interest is if they showed such care and controlover the things in the lounge which looking at their policy they did not.

Waverly BC v Fletcher 1996




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Facts: The defendent was using a metal detector in a park owned by the claiment council andfound a broach. He reported the broach and the Corner decided that the broach was not a treasuretrove. The issue then was who did he broach belong to?

Judgement:

The Court of Appeal held that the claiment had a better right to the broach as it was found within

the land, it was attached to the land rather than on the surface. It belonged to the party who ownedthe soil.

Importance:

This and the Parker case are cases which show that possession of a good is not sufficient, whetherthe owner has exercised contract and the positioning of chattels is important too. They are a goodcases to compare adverse possession too.

Walliiss Cayton Bay Holiday Camp Ltd v Shell-Mex and BP Ltd 1974

Facts: The plaintiffs had a holiday camp and the defendants had adjoining land which they had nouse for in the present, but plan to in the future. The plaintiffs farmed the defendants land for 10 yearsand then used it for the purposes of their holiday camp. After 12 years, the defendant realised they

could not use the land as intended and wrote to the plantiffoffering to sell them but the plaintiffsignored them as once the 12 years was complete they claimed adverse possession.

Judgement:

Adverse possession had not taken place. The mere fact that someone had entered land and used itfor some seasonal purpose for more than 12 years was not sufficient for adverse possession. Theclaiments were given a license or a permission from the defendant implicitly and thus possessionwas not adverse,

Importance:

This case is important in demonstrating the implied license doctrine which was reversed in the

Limitation Act 1980 Sch 1 8(4).

Bruton v London and Quadrant Housing Trust 2000

Facts: The defendants were given a license for a property by the council to house homeless people.The council retained limited access to the house as it was a license agreement. As the claiment waspaying a weekly rent to the defendent he argued that under the Landlord and Tenant Act, thedefendant had an obligation to repair the flat. However, the defandant argued that nemo dat nonquad habet, as they only had a license how could they possibly give out a lease.

Judgement:

The court ruled that the agreement looked more like a tenancy than a license and thus ruled that anon-proprietary lease had been created. This interest was seen more as an anomaly to try and notcompletely abolish the validity of the nemo dat principle.

Importance:

Some commentators suggest that the judgement was derived on policy grounds to protectindividuals enjoying exclusive possession.

Re Cohen 1953

Facts: A husband and wife lived in the property of the wife. After both died (at different occassions)

banknotes in unusual pleaces such as kitchen cabinets were found.

Judgement:




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The courts said that this money should go to the wifes estate as she is the landowner, exercisedcontrol over the property even when the husband past away.

Importance:

This case estabilished the legal principle that the landowner, the person who possessed the land isalso the owners of chattels found on it, subject to teh condition that possessionand control can be

demonstrated.

Costello v Chief Constable of Derbyshire Constabularly 2001

Facts: The defendant seized a car from the plaintiffunder statute as they believe the car to be stolenbecause the true owner was unknown. However, the defendant never brought criminal proceedingsand neither did they return the car.

Judgement:

The Court of Appeal ruled that police under statute had a possessionary title to the car for aspecificed statutory period which had ended, and the plantiffwhether he was the owner or not had a

superior possessory claim to the car than the defendant as he demonstrated intention to possessionand control of the car.

Importance:

In the English legal systems even the paper owners and those who acquire land through possessionhold relative titles. If no one else, our titles will always be relative to the crown.In Australia, theBritish Crown had got Radical Title. This title was relative and that is why at the time it could existalongside Native Title. However, the Crown transformed this into a full-beneficial title by mixingtheir labour and thus extinguishing Native Title

Doctrine of Implied License

The doctrine of implied license was used to show why adverse possession could not taken placeif possession wasnt adverse i.e. against the wishes of the paper owner.

For example, if the use of the possessor was that of the use of the paper owner then the courtsused to believe that there was an implied license permitting possession and therefore could notbe adverse. A non adverse possession related example is that when you allow a guest into yourhouse there is an implied license that you give them permission to access your bathroom (youcan already see the issues with the validity of this doctrine emerging).

A example case which you will find in cases section is Walliss Cayton Bay Holiday Camp Ltd vShell-Mex and BP Ltd.

Sch 1 Para 8(4) Limitation Act 1980 reversed this by stating: For the purpose of determiningwhether a person occupying any land is in adverse possession of the land it shall not be assumed byimplication of law that his occupation is by permission of the person entitled to the land merely by virtueof the fact that his occupation is not inconsistent with the latters present or future enjoyment of theland.This provision shall not be taken as prejudicing a finding to the effect that a persons occupation ofany land is by implied permission of the person entitled to the land in any case where such a finding is

justified on the actual facts of the case.

Essentially what this legislation is saying is that this fictitious doctrine of implied license is no

longer to be assumed by law.

Problem Question 1




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Q: Fred owned a large field which he intended to develop into a retail development in thefuture. In 1994 Matt and Vicky climbed over the fence surrounding the field and pitched atent. In 1995 they installed a gate in the fence, which they locked. In 1996 they made theirhome more permanent, using wood and plastic sheeting. In 1997 they are joined by theirfriends Nathan and Jasmin. In 2003 Matt and Vicky decide to emigrate, Nathan and

Jasmin remain on in the home Nathan and Jasmin built. In 2008 Fred sells the field toPetra who wants to develop the land. They have found Nathan and Jasmin, who arerefusing to move out.

Who would own a collection of gold coins what Matt found when he was digging thefoundations for the fence posts. They were hidden under a piece of wood in a rabbitwarren.

A: The issue here is who would the gold coins belong to Matt & Vicky, Petra or Nathan andJasmin. This is dependent on whether the coins were found in a rabbit warren under the surface of

the land or on top of the land (not annexed).

It is likely that the coins were found underneath the land because rabbit warrens usually are foundthrough a hole in the ground. However, let us first consider if it was found on top of the land. Thiswould render the coins a chattel and the typical rule is those in possession of the chattel are theowners so this would be Matts. For example, in Parker v British Airways board a gold braceletfound by a guest in an airport lounge was deemed to be the finders as the landowner did notexercise control and exclusive possession over the land and so the person with the possession wassaid to have a better claim. However, we must also consider that the coins may belong to the crownunder the Treasure Trove Act 1996. If they fit the criteria to classify as treasure then they would be

deemed to belong to the Crown which is most probable as they are gold coins.

However, as mentioned previously it more like that the coins were found under the ground. Thegeneral principle here is then that the item in concern belongs to the land as it is attached to theland. For example in Waverly v Fletcher, a claiment was using a metal detcher in a park and found abroach and as the broach was found under the surface it was said to be the landowners even thoughthey did not exercise control over the land and in Elwes v Brigg Gas Co 1866, a prehistoric boatfound undergroun was said to the landowners not the builders as it was found under the ground.

This rule means that if the coins are found under the ground we must find out who owns the land tosee who is the owner. Again there are multiple parties involved, Petra will argue that as she haspurchased the land she is the land owner but Nathan and Jasmin might argue they are the landowners as through Matt and Vicky they have adversely possessed the land.

Adverse possession is a process whereby land ownership changes by virtue of possession of the landand derives its existence from the Limitation Act 1980 s.15. In this statute, it is stated thatlandowners have 12 years to bring a claim for a property. Primae Facie, Matt & Vicky moved in1994 and as it is currently past 2006, it seems adverse possession has had the required possession forthe land to transfer.




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However, in order to estabilish adverse possession there are three conditions which possessors mustestabilish. The first is that there has been factural possesion and by this we mean physical evidenceand physical possession of the land. Powell v McFarlane is the case authority in which Slade LJprovides an in-dept judgement on what is meant by factual possession. He says it is not sufficient foran induvidual to use the land for profits more than 12 years to count as possession, there must bestrng evidence and there are few things that count as indefinate evidence such as enclosure, locking

or blocking only entrance to the land at all times from the world as well as the paper owner. In thiscase in 1995 a lock was fitted which only Matt&Vicky and then Nathan&Jasmin had access towould probably be sufficient to count as factual possession. The only caveat would be that the 12years would start from 1995 and so as again we are past 2007, we can say the limutation act haspassed the owner.

The second condition is Animus Possendenti i.e. the intention to possess. This been particularlyproblematic in certain cases. The rationale for this requirement was that originally the courts lookedat intention as a way of working out whether there was any form of permission or license for thepossessor to be on the land. Nowadays, however, the intent to possess is typically measured by

looking at factual possession and evidence of the intention the possessors claim to have and that thepossessing was for the squatters benefit not for the landowner. For example, in BuckinghamshireCC v Morgan, the defendant used the claiments land as a garden and maintained it for than 12 yearsand that was enough to show intent. Furthermore, the intention must be specific to possession notacquiring the land as saw with Lodge v Wakefield where a party convinced they already own theland ended up adversely possession the land, it is more than they intent to possess. As factualpossession was estabilish with the current case a strong case for animus possendendi can be made.Furthermore, as they have never contacted the paper owner to buy the property and it has beenover 12 years it is clear the intention has been to possess and use the land for shelter as opposed toacquiring the land.

The third requirement, not always stated as a requirement, is that possession should be adverse andby that we mean that it doesnt benefit the paper owner or is against the wishes of the owner. Forexample, as the plan to build a land by possessors was the same as the paper owner and morecrucially offers had been made to sell that property to the possessors in Walliss v Shell-Mex it wasrendered that adverse possession had not taken plce as there was an implied license. It is importantto note this doctrine was reversed in the Limitation Act 1980 Sch 1 8(4) which stated that impliedlicenses will no longer be assumed in law. Clearly as Fred had an intention to develop it into a retailpark and so did Petra whereas the possessors merely wanted it for residence, the possession wasadverse.

Now that we have estabilish that adverse possession is capable of having been processed, how to weestabilish what has actually happened in terms of the legal titel and who owns the land and thus allthat is underneath including the gold coins. This is largely dependent on whether the land isregistered or unregistered.

If the land is registered, and given that the 12 years ended after 2003, The Land Registration Act2002 states that the paper owner still has the better title unless the possessors apply to the LandRegistry. So Petra would have the authority to chuck Nathan & Jasmin out unless they can apply to

Land Regustry and get the title changed and even in that case it would give Petra a 65 working dayslot to object to the posseessors and offer her a further two years to evacuate them. If however, theland is unregistered then s17 of the Limitation Act 1980 will apply and the land will automatically be




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transferred to Nathan and Jasmin as Matt and Vicky have left. This would mean that the gold coinwould belong to them and that the sale is actually void because of the nemo dat quad non habetprinciple as that states that you cannot sell what you dont have and Fred would have lost his title in2007 and thus would not have been able to sell it to Petra.

So, in sum, then if the gold coins are found on top of the land and are treasure they belong to theCrown, if not belong to Nathan and Jasmin. If However, found underneath the ground they belongto the owner. If the land is registered then Petra is owner and can only keep the coins but commandNathan and Jasmin to evacuate the premises. If however, land is unregistered Nathan and Jasminare the legal owners and have the rights to the coins.

It is important to note under Sch 6 para 11 LRA 2002, adverse possession relies on periods ofpossession rather than the identity of the possessors and thats why adverse possession able to takeplace over the course of Nathan & Jasmin, and Matt & Vicky.

Adverse Possession of a lease

1. A typical scenario will look like; that the freeholder will create a lease with a tenant, againstwhose wishes a third party will adversely possess the land to get possession.

2. (Unregistered land) If this happens, this will not end the lease and the tenant will be liable.

3. (Unregistered land) For breaking the covenants on the lease, as the adverse possessors are thirdparties are cannot be directly sued.

4. (Unregistered land) However, the freeholder may claim forfeit for the breaches the tenant hasmade and give him the right to immediate possesion and authority to eject the adverse

possessors offthe land.5. (Unregistered land) It s only when the lease runs out and a further 12 years has expired that the

adverse possessor can make a claim on the land.

6. (Registered)As soon as the squatter takes possession of land that is leased, time runs againstthe tenant.

7. Time does not run against the landlord until the lease expires unless the adverse possessionstarted before the lease, in which case time will continue to run against the landlord during theterm of the lease.

Determining Adverse Possession in problem questions

In reality it is the character and the value of the property that determines whether the activity issufficient to show factual possession and subsequently adverse possession. Here are some examples.

- In rural land sometimes shooting of rabbits is enough as seen in Red House Farms v Catchpole

- In Boosey v Davis, the grazing of goats was insufficient to show adverse possession becausequality and quantity of such acts were minimal.

- Similarly in Tecbild v Chamberlin, the playing of children and tethering of ponies was notsufficient for adverse possession.

- In Powell v McFarlane, some farming activity and using it for advertising was insuffi

cient to countas adverse possession.




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- In Williams v Raftery, the growing of vegetables and breeding of greyhounds was said to beinsufficient again.

- In Treloar v Nute, infilling of a gully was sufficient to count



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