Wyldecrest Parks (Management) Ltd v Susan Kram & Ors
Decision date: 20 November 2025
Neutral citation: [2025] UKUT 375 (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 Wyldecrest overcharged residents of Tranquillity Park by billing them for electricity partly supplied free by on-site solar panels. The Upper Tribunal upheld the FTT's substantive finding that residents were overcharged because Wyldecrest had not paid for the solar-generated power yet charged residents for it, and directed repayment of £39,194.92 less amounts unpaid by some residents. The Tribunal set aside the FTT's directions to prepare a reconciliation and to certify sub-meters, and held that the residents' association was not an appropriate applicant.
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, on the facts and standard form agreements considered, a site owner cannot charge residents for electricity which the owner has not paid for to an authorised third‑party supplier; and that the Maximum Retail Price Direction does not operate to permit charging residents for on‑site solar generation supplied to the site owner at no cost.
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 suggests (obiter) that a site owner wishing to recoup investment in or otherwise deal with on‑site solar generation should consult residents and amend agreements by consent rather than attempt to recover costs under standard utility clauses, and that leased solar/feed‑in arrangements materially affect MRP calculations and transparency obligations.