A house reasonably so called

There must be few provisions which have taxed the senior judiciary quite as much as s 2(1) of the Leasehold Reform Act 1967. The seemingly simple question of “what is a house” for the purposes of the right to enfranchise under the Act, has been considered by the House of Lords/Supreme Court three times since 1982 (Tandon v Trustees of Spurgeon Homes [1982] AC 755, [1982] 1 All ER 1086, Boss Holdings Ltd v Grosvenor West End Properties [2008] UKHL 5, [2008] 2 All ER 759, Day v Hosebay Ltd; Howard de Walden Estates Ltd v Lexgorge Ltd [2012] UKSC 41) and by the Court of Appeal three times in as many years (Henley v Cohen [2013] EWCA Civ 480, [2013] All ER (D) 36 (May); Earl Cadogan v Magnohard Ltd [2012] EWCA Civ 594, [2012] All ER (D) 47 (May)).

Section 2(1) provides: “For the purposes of this Part of this Act, “house” includes any building designed or adapted for living