Mohammed Abid Zaman v Leeds City Council
Decision date: 7 May 2026
Neutral citation: [2026] UKUT 180 (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 a building that meets the converted building test and is an HMO under s.254(4) of the Housing Act 2004 can nonetheless have each flat treated as a "house" for Part 3 selective licensing. The First-tier Tribunal held and the Upper Tribunal accepted that each of the four residential units at 1 Cranbrook Avenue was subject to selective licensing and that separate financial penalties could be imposed for each flat. The Council's imposition of four separate penalties was therefore upheld in principle.
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 converted building test in s.254(4) identifying a building as an HMO does not automatically prevent individual dwellings within that building from being "houses" for the purposes of Part 3 selective licensing; Part 3’s definitions (including s.99) permit separate self-contained units within a building meeting s.254(4) to be treated as licensable houses, allowing separate penalties to be imposed for each unit.
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 observes (obiter) that the statutory architecture requires careful interpretation when considering the interplay between Parts 2 and 3, and that differences in prescribed descriptions and occupation numbers may lead to different licensing outcomes for Parts 2 HMOs and Part 3 selective licensing.