Angelo Perotti v Amboh Properties Limited
Decision date: 16 December 2025
Neutral citation: [2025] UKUT 421 (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 appeal concerned whether a s.13 Housing Act 1988 Form 4 notice which proposed a new rent expressed as a monthly sum was valid for an assured periodic tenancy where rent had historically been payable quarterly. The First-tier Tribunal ultimately held the original notice valid, converted the proposed monthly figure into an equivalent quarterly sum and fixed a new rent of £1,150 per month (equivalent £3,450 per quarter) effective 20 May 2025; the Upper Tribunal dismissed the landlord’s challenge. The landlord’s later served notice and purported withdrawal of the original notice did not defeat the FTT’s determination and the appeal.
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
From the judgment as recorded in the notes, a s.13 Form 4 notice expressed in a different periodicity to the tenancy can be treated as valid provided it complies with the statutory requirements as to the commencement date and minimum notice period; the date specified in the notice is decisive for validity because it identifies when the new rent period begins and the tenant’s referral deadline.
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 notes record observations that the FTT may form and express provisional views on notice validity for jurisdictional purposes without precluding other determinations (including in the County Court), and that a landlord cannot unilaterally withdraw a notice once the tenant has referred it to the FTT; these points were treated as ancillary comments rather than central holdings.