Oxford Hotel Investments Limited v Great Yarmouth Borough Council
Decision date: 24 November 2025
Neutral citation: [2025] UKUT 387 (LC)
Overall AI summary confidence: high
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: high
This appeal concerned whether provision of a microwave in hotel rooms amounts to "cooking facilities" under s.254(8) Housing Act 2004 and whether the presence of any single basic amenity prevents a building meeting the s.254(2)(f) standard test for an HMO. The Upper Tribunal held that a microwave alone does not constitute cooking facilities and upheld the FTT's finding that the building lacked required amenities, confirming the HMO declaration for the St George Hotel.
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: high
The tribunal applied the statutory purpose and scheme to interpret "cooking facilities" in s.254(8) and concluded that mere provision of a microwave is insufficient to meet that concept; likewise, the language of s.254(2)(f) contemplates lack of one or more basic amenities, so the presence of a single basic amenity does not negate that limb of the standard test.
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 judgment included cautionary observations that treating minimal electrical items (like a power point or microwave) as sufficient cooking facilities would be impractical and contrary to legislative purpose, and noted an instance of misattributed authority where a cited passage (purporting to support that microwaves qualify) was not actually in the authority relied upon.