Not even holy ground escapes compulsory purchase,  places of worship are acquired much like other land: see London Transport v Congregational Union [1979]. Expropriation in the UK comes under scrutiny as emotions run high with projects such as Crossrail, HS2 and two new nuclear power stations in the pipeline. But how can the UK’s compulsory purchase system change to make projects more efficient, while being more transparent and fair to those affected?

It helps to understand the origins of the principles behind statutory compulsory purchase. The story starts with the emergence of the individual as a person protected in some way against the State (or Crown). The first half of the Middle Ages was characterised by manorialism and feudalism.¹ Feudalism is commonly understood, however the lesser known manorialism refers to community life centralised around the manor, with agricultural work provided to the local lord by the common man in exchange for his subsistence. These systems became disrupted, in part due to the emergence of a market economy, where produce and interests in land began to be bought and sold with money. Gradually over the last millennium, the individual has emerged, and the key juncture in the form of the Magna Carta of 1215 came as a direct challenge to unbridled feudalism, bestowing a certain class of individuals with rights upheld against the primacy of the English Crown. There were similarly inspired agreements on the Continent, starting with the Hungarian Golden Bull edict of 1222 or ‘Aranybulla.’ Folklore tells that European knights together out on crusade conspired in their demands for the emergence of fundamental rights across Europe. What is more certain is that the agreements were reached as a response to the decline of the manorial and feudal power structures. The most famous clause 39 of the Magna Carta reads²:

“No free man shall be seized, imprisoned, dispossessed, outlawed, exiled or ruined in any way, nor in any way proceeded against, except by the lawful judgement of his peers and the law of the land.”

Our focus is the issue of dispossession according to the law. In England compensation for dispossession was soon commonplace where the Crown lawfully fulfilled its responsibility for transport by road and river. 1539 brought the first statutory compulsory purchase,³ that is, one by an act of Parliament under royal prerogative, rather than by the  Crown itself. Land was taken for the cutting of a canal giving by-water access to Exeter, and compensation was paid at 20 years rent. 

This system of passing specific ‘private’ or ‘local’ acts to authorise compulsory purchase continued act-by-act until the Lands Clauses Consolidation Act 1845, which codified the conditions for compulsory purchase; this could then conveniently be incorporated into future acts by reference. The main provisions from the 1845 Act can today be found in the Compulsory Purchase Act 1965 and the regulations governing compulsory purchase in England are to be found in⁴:

• The Acquisition of Land Act 1981 in the form of the most common Compulsory Purchase Order (CPO). 
• The Transport and Works Act 1991, tailored towards railways and trams,⁵ and more recently:
• The Planning Act 2008 in the form of the Development Consent Order (DCO), for large, Nationally Significant Infrastructure Projects (NSIPs).⁶ 

Today the rights found in clause 39 of Magna Carta, generally, can be found in the European Convention on Human Rights, to which the UK is party, and which entered into force in 1953.⁷ 

Reform in the UK 

‘It has been widely acknowledged for over two decades, however, that the law of compulsory purchase in England and Wales is fragmented, hard to access and in need of modernisation. 

  The Law Commission 2004⁸ 

There have already been attempts to reform the compulsory purchase system in the UK. Successful changes were made to the tribunals system under the Tribunals, Courts and Enforcement Act 2007, the old Lands Tribunal was replaced by the Upper Tribunal in 2009,⁹ with the First-tier Tribunal (Property Chamber) now active at the time of writing.¹⁰ The Law Commission have been developing ideas around a Compulsory Purchase Code, – not to be confused with a civil law code.^11,12 The recommendations of the Law Commission have not been implemented.^8,13 For the sake of creating a novel publication, we will refrain from recycling suggestions here that have been made elsewhere. 

Injustice

In a perfectly just world, compensation would be paid for any kind of genuine disruption due to a scheme, but law cannot permit this, if it did the floodgates would surely open… ‘to a liability in an indeterminate amount for an indeterminate time to an indeterminate class’: Cardazo C.J. in Ultramares Corp. v Touche (1932) (US). 

In an imperfect world there are injustices. For example, in a rural setting where land and farmer become strongly linked, schemes sever farms; permanently in the cases of road and rail. Often along a route all those affected take part in an over-competitive and inflated local market as they seek new land or premises to marry what they have left; this is a market which the compensation they have been given does not necessarily reflect. Issues of land concentration, which makes suitable sized plots of new land difficult to find, add to the problem.¹⁴ Those who move to new and more costly premises, perhaps with limited alternatives, are all too often told that they have ‘received additional value;’¹⁵ that is that the new property offers certain advantages the old property did not; they are therefore not to be compensated based on the new cost despite having little choice in the matter. 

Agricultural, commercial, whatever the setting; those whose land is acquired are not entitled to direct compensation for all profits lost as a result of the acquisition. The traditional argument goes that future profits in a ‘no-scheme world’ are automatically rolled into the market value of the land already compensated for and therefore merit no further compensation.¹⁶ ‘Goodwill’; that is, the profits developed by the occupier above and beyond the profits derived from the land itself, are however admittedly compensatable.¹⁷ However it seems that the degree to which the standard profits are rolled into a market value could be too easily overestimated, and the true value of the ‘goodwill’ element too easily underestimated. The classic case cited, despite the flawed nature of the plaintiff’s claims, is ‘the fish and chip shop case’: Mohammed & Ors v Newcastle City Council [2016] where an (unsuccessful) claim based on loss of profits was attempted. 

One option stands out as a cure to these two key injustices; perhaps the re-introduction of the ‘solatium’ that existed universally in the UK before 1919; that is; the paying of a premium upon the compulsory acquisition of all interests in land; would compensate more fairly the reality of compulsory purchase for those who live under the cloud of compulsory acquisition.¹⁸ 

Moreover, the giving of offers ‘subject to contract’ by acquiring authorities also expose those affected by expropriation to unduly harsh circumstances. Where the acquiring authority makes an offer following a notice to treat, they can mark the offer ‘subject to contract.’ A typical claimant may then depend upon this offer, or even secure bridging finance, to acquire a new property. But the offer is not set in stone, and the acquiring authority can turn around and slash the price, leaving the claimant in an ‘impossible’ position as they have already arranged to purchase another property.¹⁹ 

What happens when the acquiring authority enters or takes possession of land without the appropriate powers, surely such an affront to fundamental rights would be taken seriously? 

If the acquiring authority should enter unlawfully there is a fine of £10 payable.²⁰ There is the obligation to compensate any damage done in entering unlawfully, but nonetheless the almost complete lack of compensation for an act against the fundamental rights of the landowner seems quite unwarranted. The reason for entering the land (unlawfully) would likely be in connection with the building of infrastructure or significant development, usually with millions of pounds of investment involved, and we know the sums paid by willing developers and utility companies for land interest questionnaires and non-intrusive licences are in the hundreds of pounds, so to pay pittance for a breach that is significant in principle seems dissatisfactory. There will be professional fees for the landowner to pay in fighting such an ingress. Even where a claimant seeks redress at common law for damages for trespass such as in National Provident Institution v Avon County Council [1992], the damages paid can be minimal. Here demolition was undertaken by the acquiring authority on the land of the plaintiff, on whose land no compulsory purchase powers existed. The damages paid to the claimant were only £200 in today’s money.²¹ Crucially; court legal costs were payable by the plaintiff as it was deemed they had effectively lost the case against the acquiring authority. So there is no right to significant damages based upon the fact that works have been carried out on land with no confirmed CPO, and claimants should be held back for fear of the costs of litigation. All this together puts the developer in an unusual position of power, with scope for negligence without consequence. There is a natural inclination to support the underdog; but the metaphorical boot is on the authority’s foot. 

These last two injustices could be legislated against effectively; firstly, by making offers of the acquiring authority final from their side; that is, each time the landowner accepts an offer of the acquiring authority, the acquiring authority should not be at liberty to withdraw or change the offer. The issue of entry without consent could be tackled with a fine based upon the yearly turnover of the acquiring authority or the total value of the scheme, this hopefully proportionally ensuring increased respect and caution on the behalf of the acquiring authority. 

Comparison with a Civil Law Jurisdiction

It is interesting to consider a civil law jurisdiction, where judgements are (commonly assumed) to follow a civil code, rather than a combination of statute and case law. Judges in civil law jurisdictions do in fact draw inspiration from case law depending upon the jurisdiction; there is a good talk by Holger Spamann of Harvard Law School on this topic.²² 

At the turn of the century Vienna was the capital of the Austro-Hungarian Empire, with the Civil Service, and its civil codes as the jewel of its crown. Today Austria is a federation of nine states of which Vienna is the largest by population. Each state has their own Bauordnung (BO) or Building Law.²³ The core principles for compulsory purchase and compensation in Vienna are set out in the Bauordnung für Wien in sections 38-46, with sections 57-59 reserved explicitly for the issue of compensation.²³ There have recently been infrastructure projects with significant expropriation consequences such as the U2/U5 U-Bahn (Underground Mass-Transit) extension, which will conclude in 2028.^24-26 Notwithstanding significant projects in a large city the application form for compulsory purchase under the Bauordnung für Wien is only one page long.²⁷ 

Other states in Austria have similarly compact civil codes which have provided for the building of vast projects like the Brenner Autobahn (Brenner Pass Motorway), in Kärnten (Corinthia), this motorway forming a backbone of European North-South transit. Indeed the Kärntner Bauordnung or Corinthia Building Code has a total of only around 50 sections and articles (50 paragraphs).²⁸ Infrastructure expansion continues: the question as to why Austrians dwelling in sleepy valleys should have their homes compulsorily purchased to make way for freight between Germany and Italy is frequently a hot topic on ORF radio.²⁹ 

There are also federal laws (Bundesgestze) that deal with compulsory purchase for particular types of infrastructure and development. These include:

• Eisenbahn-Enteignungsentschädigungsgesetz or Railway Expropriation Compensation Law, the EisbEG. 
• Bundesstraßengesetz or Federal Roads Law, the BStG 1971.
• Bodenbeschaffungsgesetz of 1974 or Land Procurement Law. See the recent circumstances in Innsbruck.^30,31 

These federal laws carry out a similar function to the ‘enabling acts’ in UK compulsory purchase law. 

All of the same main principles of expropriation run through the UK and Austrian legislation. However, looking more closely at the Austrian legislation; it has a different style to the UK legislation. The UK legislation reads much like ‘computer-code,’ with single lines of text linked logically in a kind of ‘if’, ‘only-if’ fashion. In contrast, an Austrian section consistently consists of one paragraph of medium length, altogether describing, framing, in the most reasonable way the issue it seeks to address and its context. Rather, the UK legislation is written in a rather paranoid fashion, perhaps constantly seeking to prevent circumvention of parliament’s intent; but surely a member of the judiciary would spot an advocate who seeks to interpret vexatiously. 

Perhaps we could incorporate more of the Austrian style into our legislation, particularly when starting from scratch, as would be the case if writing a compulsory purchase code. The legislation should be less prescriptive and more descriptive. The Austrian approach requires that judges are allowed to gather just interpretation from legislation, rather than apply it letter for letter, judges must therefore be permitted significant freedoms. It is interesting that the old Lands Tribunal in the UK was not bound by precedents set by itself, although it was bound by decisions of the Court of Appeal.³² 

Accessibility and Efficiency

Statute and case law have different characteristics, statute is a precise prescription, the interpretation of which is limited and constricted, but it can be made fairly rapidly by the two houses of Parliament. Case law provides inspiration for just interpretation, but for it to be made the correct case must present itself, and new precedents are restricted in that they can only follow as adaptation and evolution of existing case law. Statute and case law must be used in the correct circumstances respectively to achieve the most efficient law.

The principles of compensation law in the UK are scattered amongst ten or so statutes (excluding enabling acts, and there is a clear benefit to having a different act for each kind of infrastructure or development). As compensation law has grown it has inevitably become more complex, however this increase in complexity could likely be reduced significantly through the considerable task of centralising all of the current principles into one, two, or possibly three comprehensive statutes.

Codification: some areas of law are unjust or outmoded or have become overly sophisticated, and this is a clear impetus to codify. But codification and re-codification can create serious problems; take for example the most recent Electronic Communications Code brought in by the Digital Economy Act 2017. There have been significant teething problems with this new code, with polarisation of claims and significant litigation taking place, partly because of an over-literal interpretation of the code regarding rent: in CTIL v Compton Beauchamp [2022], CTIL, otherwise Cornerstone Telecommunications, tried to interpret the new Code to produce a rent of £26 per annum for a mast site. This is clearly dissatisfactory as no willing landowner would accept this figure.³³ 

Finally; legislation becoming outmoded is inevitable, but excessive sophistication is less forgivable:  s. 14(3) of the Land Compensation Act 1961 regarding compensation and planning permission reads: 

‘Nothing in those provisions shall be construed as requiring it to be assumed that planning permission would necessarily be refused for any development which is not development for which, in accordance with those provisions, the granting of planning permission is to be assumed…’ 

This kind of composition wastes time and is apt to produce unfortunate misinterpretation; it shouldn’t be difficult to avoid. 

Three Parties to a Compulsory Purchase

Lord Denning in Prest v Secretary of State for Wales [1982]:

‘I regard it as a principle of our constitutional law that no citizen is to be deprived of his land by any public authority against his will, unless it is expressly authorised by Parliament and the public interest decisively so demands…’

Building upon the theme of the public interest laid down by the ECHR and Denning’s comment above in Prest regarding balance of the public interest and compensation: it is an interpretation that compulsory purchase is not just an exchange between the acquiring authority and they who have an interest in the relevant land. It is rather a tripartite interaction between landowner, the acquiring authority, and crucially the public, for the acquiring of the land hinges upon the transaction being in the public interest.³⁴ In the words of Lord Greene MR: ‘There is a third party who is not present, viz., the public’  in B Johnson & Co (Builders) Ltd v Minister of Health [1947]. Following privatisation of utilities, road, rail and airports, we have to ask who expropriations under privately owned acquiring authorities really serve; do they sacrifice the land of occupants in the interest of the public, or in the interest of FTSE 100 shareholders?

And so why not, with projects ranging from local developments up to NSIPs, give the public a say on whether projects requiring expedient compulsory purchase of extensive private property should go ahead. Switzerland has a pervasive system of referenda at both the federal and cantonal (local state) level with multiple federal level referenda per year. There have been Swiss referenda on infrastructure projects, including hydro-power schemes and dams in particular.³⁵ Electronic voting is highly enabling and as our democracy evolves, referenda could be an effective way to create mandates for infrastructure projects at a local level and at a national one. It is unclear whether projects put to referendum would be stymied at the local level by ‘NIMBYism’ or whether large infrastructure projects would be vindicated as the many the projects serve vote against the minority who are negatively impacted. 

The Information Age

Digitalisation provides significant scope for more efficient delivery of nationally important projects which require compulsory purchase. The success of the digital tools employed by the Rural Payments Agency in delivering subsidies under the Basic Payment Scheme (BPS) shows how digital mapping and land parcel referencing can be highly effective for agricultural holdings. Utilities agents have already started to develop their own software which they use to negotiate and interact with clients and those affected by compulsory purchase for infrastructure projects such as pipelines and grid connections.³⁶ Yet it remains to be seen if software can be developed that deals with land interests in an urban setting, such as, for example, central London. The question is whether the software can be developed in a way that makes information about interests in land manageable for the user.³⁷ Indeed in a city, as ownerships and burdens are stacked on top of each other and intersect so frequently the entry of the data and its interpretation become less intelligible. 

A significant barrier to compulsory purchase being carried out efficiently and fairly is the process of deciding where infrastructure links or developments will go. Although surveyors do form Land Interest Groups to represent their clients’ interests more effectively, agents representing the acquiring authority will typically meet with clients and those who act for them one-by-one. This means that information about the preferences of the acquired is submitted in a piecemeal fashion and often not made coherent with the preferences of neighbours. Perhaps it is time to formalise a digital system where those with interests of land can express which assets mean the most to them, so that different parties’ priorities can be set off against each other. Software development is now advanced enough that a system could be created where landowners are given, for example, fifty points for every £100,000 of property they own. Landowners would then distribute these points to land interests they own on a digital map that includes land parcels and real-estate. The final route of the infrastructure link is then digitally optimised to avoid areas of high priority/intensity/interest, with a numerically defined path that provides minimal disruption. Could this be the future of route determination for large infrastructure links and pipelines?

Initially we came to the conclusion that the current system is skewed in favour of acquiring authorities, with little room for sentiment on the part of those acquired. There are indeed a few injustices to be found, a realistic remedy to compensate being the re-introduction of a bonus payment or ‘solatium’ over and above the market value of land acquired, as existed pre 1919. To make the relevant law more easily understandable and efficient, legislators, drafters and judges need to use statute and case law in their proper places respectively. Indeed Austrian expropriation law demonstrates that it is possible to legislate even for large infrastructure projects using a compact code. An overhaul in the form of a single compulsory purchase code may be necessary. Digitalisation provides possibilities for mapping and prioritisation of interests parties have in land. Furthermore, digital direct democracy in connection with local and nationally significant infrastructure projects provides significant opportunities for increased efficiency, transparency and justice.

UK Statute

Lands Clauses Consolidation Act 1845

Land Compensation Act 1961

Acquisition of Land Act 1981

Transport and Works Act 1991

Tribunals, Courts and Enforcement Act 2007 

The Planning Act 2008

Digital Economy Act 2017 

Austrian Legislation: State

Bauordnung für Wien StF.: LGBl. Nr. 11/1930

Kärntner Bauordnung 1996 StF: LGBl Nr 62/1996 (WV)

Austrian Legislation: Federal 

Eisenbahn-Enteignungsentschädigungsgesetz:  EisbEG: StF: BGBl. Nr. 71/1954 (WV)

Bundesstraßengesetz StF: BGBl. Nr. 286/1971

Bodenbeschaffungsgesetz StF: BGBl. Nr. 288/1974

Case Law: UK

Ashbridge Investments Ltd v Minister for Housing and Local Government: [1965] 1 WLR 1320, [1965] 3 All ER 371

Associated Provincial Picture Houses Limited v Wednesbury Corporation [1948] 1 K.B. 223

Birmingham City Corpn  v West Midlands Baptist Trust [1969] UKHL, [1970] AC 874, [1969] 3 All ER 172

Attorney-General v De Keyser’s Royal Hotel [1920] UKHL 1, [1920] AC 508

B Johnson & Co (Builders) Ltd v Minister of Health [1947] 2 All ER 395 

Cornerstone Telecommunications Infrastructure Ltd (Appellant) v Compton Beauchamp Estates [2022] UKSC 18

London Transport Executive v Congregational Union of England and Wales Inc (1978) 37 P & CR 155, [1978] RVR 233, 249 Estates Gazette 1173

Mohammed & Ors v Newcastle City Council [2016] UKUT 415 (LC)

National Provident Institution v Avon County Council [1992] EGCS 56

Prest v Secretary of State for Wales (1982) 81 LGR 193, 198

Roberts v Coventry Corporation [1947] 1 All E.R. 308

Street v Mountford [1985] UKHL 4, AC 809, 2 WLR 877

Case Law: US

Ultramares Corp. v Touche 174 N.E. 441 (1932) (US)

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