Harnek Singh Samra & Anor v Sandwell Metropolitan Borough Council

Decision date: 27 February 2026

Neutral citation: [2026] UKUT 83 (LC)

Overall AI summary confidence: medium

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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: medium

This case concerns valuation and consequential compensation under the Land Compensation Act 1961 for a partially developed site at 103 Barclay Road and an adjacent site, vesting on 7 May 2014 after a compulsory purchase. The Tribunal assessed how pre-vesting works carried out by the claimants and reasonable remediation obligations for neighbouring properties affect the hypothetical purchaser's valuation and resulting compensation, and determined the compensation payable; the acquiring authority carried out selected remedial works (option 3A) to neighbours post-vesting.

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

When valuing a partially developed site acquired by compulsory purchase at the vesting date, the valuation must reflect works the claimants carried out before vesting and take into account reasonable remediation works required for neighbouring properties as of the valuation date; the acquiring authority’s selection and execution of practical remedial works post-vesting are relevant to adjustments in consequential compensation.

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: low

The Tribunal indicated that practical constraints (for example, unimplemented pre-commencement planning conditions or on-site stabilisation measures) can influence what a hypothetical purchaser would accept or be required to undertake. It also noted that the death of a claimant without an administrator can be managed procedurally by representation with the parties’ agreement.