Nicola Johnson v The Salvation Army Trustee Company

Decision date: 1 October 2026

Neutral citation: [2026] UKUT 370 (LC)

Overall AI summary confidence: high

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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 a large Hall and a small Prayer Room in the Salvation Army's former headquarters were exempt from non‑domestic rating under para. 11(2)(b) as parts of the hereditament used for purposes ancillary to office use. The Tribunal held "ancillary" means subordinate, supplemental or incidental to office use and does not require the ancillary activity to be a generic office facility; on the facts the Hall and Prayer Room were ancillary to the building's office use and thus exempt. The Valuation Officer's appeal was dismissed and the rateable value was fixed at £1 (save for costs).

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 exemption in paragraph 11(2)(b) extends to parts of a hereditament that are used for purposes subordinate, supplemental or incidental to the primary use of the property as offices; determining ancillary status is a factual inquiry into primary purpose and subordinate character, not a requirement that the ancillary use be a facility commonly found in offices. Private religious worship may be ancillary if its use is subordinate to the office use.

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 indicated that the neutrality or multi‑faith character of a prayer room is irrelevant to the ancillary‑use assessment, and that the physical size of a room is immaterial where its primary use is shown to be ancillary to office functions.

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