Christopher Royle (Valuation Officer)
Decision date: 17 October 2025
Neutral citation: [2025] UKUT 343 (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 digital bus-shelter advertising rights should be valued at a 6:1 multiplier of static-display base values for the assessment day (AVD) 1 April 2015. The Upper Tribunal, on unopposed written representations, held the P&M Regulations were not relevant and that there was sufficient evidence to apply a 6:1 ratio, reinstating revised rateable values for the 21 hereditaments in the 2017 list. The appeal was allowed and the Tribunal directed revised RVs in the Appendix.
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 tribunal treated advertising hereditaments as governed by their own statutory valuation approach and concluded the Valuation for Rating (Plant and Machinery) Regulations 2000 do not affect the valuation of the right to display advertising on bus shelters; industry evidence and comparable decisions can justify applying a substantial multiplier (here 6:1) to static-display base values for digital displays at the relevant AVD.
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 observed that commercial agreements made after the AVD are less reliable as evidence of arm’s‑length rents, and that whether the 6:1 ratio should be applied in future valuation lists is a matter for another occasion rather than decided here.