Amanda Hitchings & Anor v Valuation Tribunal for England
Decision date: 14 January 2025
Neutral citation: [2025] UKUT 6 (LC)
Overall AI summary confidence: medium
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: medium
This case arose from two unopposed Valuation Officer appeals against Valuation Tribunal for England (VTE) decisions reducing rateable values for advertising rights on bus shelters in Manchester and Sheffield. The Upper Tribunal allowed the VO appeals, holding that on the available evidence a 6:1 digital:static multiplier for 6-sheet bus shelter displays was warranted and applying that multiplier to set the Manchester RV at £7,200 and the Sheffield RV at £2,950. No costs were ordered.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
The decision establishes that, for small-format advertising hereditaments at the relevant antecedent valuation date, industry evidence (including an industry note and VORC data) can justify applying a 6:1 multiplier to value digital 6-sheet displays relative to an agreed static tone, and that national or post‑AVD commercial portfolio agreements have limited weight when valuing individual sites for that AVD.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal noted (obiter) that scroller/rotating displays are uncontroversially more valuable than static displays (accepted at about a 3:1 ratio) and that the 6:1 ratio adopted might be reassessed for future valuation lists as market evidence evolves.