The Greater Manchester Combined Authority (GMCA)is made up of the ten Greater Manchester Councils and the Mayor of Greater Manchester. The GMCA has submitted a Joint Development Document (the Plan or DPD) to the SoS for examination on behalf of 9 of the 10 Councils. The SoS appointed an Inspector to examine the Plan. The Inspector recommended adoption of the Plan. In SAVE GREATER MANCHESTER GREEN BELT LTD v Sos for HCLG and GMCA the Claimants, who opposed the development of housing on green belt land, applied for statutory review of the adoption .The Court addressed examination of DPDs (paras27-34), challenge to a DPD ( paras 35-43), policies in the NPPF in relation to Green Belt (paras 44-101), the Examination (paras 102-108), and the Inspector’s Report (paras 109-122). All 5 Grounds of challenge were dismissed : paras 10/11 and 123).

The Government has announced changes to the Environmental Permitting System.

The Environmental Agency will be empowered to consider, following consultation, which activities should be exempt from requiring an Environmental Permit.

In CG FRY & SON LTD v SoS for Housing, Communities and Local Government (2025) UKSC 35 the Supreme Court holds that where a development has a potential impact on a PROTECTED SITE under the CONSERVATION OF HABITATS AND SPECIES REGULATIONS 2017 ( and the HABITATS DIRECTIVE as “assimilated law” and its strict “ precautionary approach”), an appropriate Environmental IMPACT ASSESSMENT under Regulation 63 can be carried out at the stage of a Decision (1) to give reserved matters approval or (2) to discharge conditions attached to such an approval where that would result in an authorisation for the project to proceed, BUT LPAs cannot at later stages of the planning process that had been approved in principle at the outline stage. Lord Sales also addressed RAMSAR SITES, designated under the RAMSAR CONVENTION and Section 57A of the WILDLIFE AND COUNTRYSIDE ACT 1981, and protected pursuant to the NPPF.

DHARMESHKUMAR v SoS & BRENT COUNCIL ( 2025) EWHC ( Admin ) is an appeal to a Planning Inspector against an Enforcement Notice served by the Council. It addresses questions about what works constitute development within Section 55 of TCPA 1990 and the interpretation of a planning decision by reference to extraneous material.

In REED V ICO ( 2025 ) UKFTT 01131 ( GRC ) on Regulation 5 of the Environmental Information Regulations, the duty to make available environmental information on request, it is held, at para 39, that the relevant time is the time at which the request is made.

R ( Williams ) v CYNGOR GWENT ( 2025 ) EWHC 2395 ( Admin ) concerns whether a planning decision had been made on a mistaken basis and whether the Officers Report and the accompanying documents were materially misleading. This was addressed at paras 35-45 inc. At paras 37 & 38 the Judge said that when considering that question “ account is to be taken of the readership “. Those to whom a Report is addressed are not planning lawyers nor planning consultants. The adequacy of the explanations contained in a Report are to be considered against the background of the local and other knowledge that readers will have.

In R ( RICKARDS ) v EAST HERTS DC ( 2025 ) EWHC 2238 ( Admin ) the Court states, at para 68, that crucially, with permitted development rights, the principle of development is already established by statute, and that what is left to consider is how that development should be implemented. At para 72 the Judge adds, in relation to lightness of touch, there is a distinction to bedrawn between considering whether permitted development rights apply and the details of the development subject to which those rights are exercised.

Public interest in the protection of the environment is firmly established. The AARHUS CONVENTION requires that party states, including the UK, ensure that members of the public have access to challenge acts and omissions which contravene provisions of its national law relating to the environment. To that end, the AARHUS COSTS REGIME is designed to ensure that environmental claims are not prohibitively expensive AND that there is REASONABLE PREDICTABILITY. In GREEN LANE ASSOCIATION LTD v CENTRAL BEDFORDSHIRE COUNCIL ( 2025 ) EWHC 2251 ( Admin ), concerned with Traffic Regulation Orders, the Court says, at para 14 : “ The rules place clear demands on both parties. Claimants must claim the Aarhus costs protection at the very beginning of a claim and must supply the relevant financial information at the inception of a clai. Defendants must notify any disagreement or desire to vary the costs cap at their earliest opportunity, namely the filing of the AoS form. It is the incumbent on the Court to make an early decision on the dispute before more significant costs are incurred. The rules are strict so as to ensure reasonable predictability at an early stage. “

From para 36, the Court addresses the question of the test for assessing whether or not a claim falls within Aarhus. The claim was found to fall within the regime.

The Judgment of the Court of Appeal in SOMANI HOTELS LTD v EPPING FOREST DC, the Bell Hotel case, is now available at ( 2025 ) EWCA Civ 1134. The Court of Appeal addresses the statutory duty and engagement of the Secretary of State at paras 50-87 inc, and the approach to interim injunctions from para 88. At para 122, the Court referred to the desirability of preserving the STATUS QUO, saying ( emphasis added ) “ Both as a matter of planning law ( because an enforcement notice cannot be used to prevent an anticipated future breach ) and as a matter of general AMERICAN CYANAMID principles there is a GREAT DIFFERENCE BETWEEN AN APPLICATION TO PREVENT A CHANGE OF USE WHICH HAS NOT YET OCCURRED AND AN APPLICATION WHERE THE ALLEGED BREACH HAS BEEN GOING ON, INTERMITTENTLY< FOR SEVERAL YEARS.”

On 29 August 2025 the Court of Appeal has allowed an appeal against the interim injunction granted to EPPING FOREST DC blocking the use of the BELL HOTEL in its area to accommodate asylum seekers pending a full hearing in October 2025. The Judge’s approach to the balance of convenience exercise and a range of public interest factors had been seriously flawed in principle and in a number of respects. In particular, it was desirable to preserve the status quo, and undesirable to incentivise protests.