Dieu Quang Tran & Anor v Stockport Metropolitan Borough Council
Decision date: 16 September 2026
Neutral citation: [2026] UKUT 354 (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 case concerns a Part I Land Compensation Act 1973 claim by Mr and Mrs Tran that 167 Stanley Road depreciated in value due to increased noise from improvements to the A555 Manchester Airport Relief Road. The Tribunal found the technical noise evidence showed no increase in noise at the property (indeed a slight reduction) and that the claimants' valuation evidence was inadequate. Because no increase in a specified physical factor was established as caused by the scheme, the Part I compensation provisions were not engaged and the claim was dismissed. No assessment of quantum was required.
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
A successful Part I claim under the Land Compensation Act 1973 requires primary proof that one or more specified physical factors increased at the claimant’s property as a result of the use of the public works; absent such proof, the statutory compensation provisions do not apply. Noise modelling that demonstrates no material increase (or a minor reduction) in noise at the property can therefore defeat a claim for depreciation even where traffic volumes on the improved highway have risen.
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 observed that where a road already existed, useful analysis compares the level of the physical factor "turned up" by the improvement, and that valuation evidence must isolate and quantify the element of loss attributable to identified physical factors at the historic valuation date; retrospective valuations of poor quality are insufficient. It also noted the practical difficulty of discerning noise-related depreciation given multiple market influences and imperfect monitoring proxies.