Guillaume Marc-Alex Guinard v Klimas Jurevicius & Anor

Decision date: 18 June 2026

Neutral citation: [2026] UKUT 226 (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 appeal concerns whether landlords who managed an unlicensed house in multiple occupation (HMO) had a "reasonable excuse" for not obtaining a licence. The First-tier Tribunal found a prima facie offence but accepted the respondents' evidence that they were reluctant landlords who had been manipulated by the tenant and had taken steps to seek the tenant's departure, and therefore had a reasonable excuse; the FTT said it would have awarded only £1 had it had to assess quantum. The FTT's decision was affirmed on the grounds advanced.

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 judgment supports the proposition that, where a tribunal accepts credible evidence that landlords were reluctant to be landlords, genuinely sought to secure a tenant's departure, and were manipulated by the tenant so as to be unable or deterred from applying for an HMO licence, those facts can amount to a "reasonable excuse" for failing to hold a licence and thus negate liability for the unlicensed-HMO offence in appropriate circumstances.

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 remarked that the local authority website was "less than clear" about exemptions, which could cause confusion, and made observations about the applicants' behaviour (including false promises to leave and exaggeration of disrepair) as relevant to the reduction of any rent-repayment award. These comments appear non-essential to the decision.