Ground F of the Landlord & Tenant Act 1954 – a guide to a landlord's redevelopment rights

If you have received a Section 25 notice or your landlord has indicated they intend to oppose your lease renewal on redevelopment grounds, it may be necessary to assess whether your landlord has the requirements for a valid Ground F claim, for example:

• Has your landlord provided detailed plans for demolition, reconstruction or substantial construction work?
• Do the proposed works affect the premises you occupy for business purposes?
• Can the landlord reasonably carry out the works without obtaining vacant possession?
• Does your landlord have planning permission or reasonable prospects of obtaining it?
• Has your landlord secured adequate funding for the development?
• Will the works commence within a reasonable time after your tenancy ends?

A negative answer to any of these questions may indicate that your landlord's Ground F opposition can be challenged.

In this article, we aim to address the most frequently asked questions regarding lease renewal issues related to Ground F.

I am a business tenant and have occupied for many years. Does the landlord have a right to oppose my lease renewal?

There are limited grounds under the Landlord and Tenant Act 1954 (the Act) which entitle a landlord to oppose a tenant's lease renewal. Those grounds are set out in Section 30 of the Act and include:

• where the property is in disrepair,
• where the tenant has persistently delayed in paying rent,
• other breaches of the tenancy,
• the landlord wishes to provide alternative accommodation.
• the landlord wants to demolish the property or redevelop it.
• the landlord offers a lease of an economically separable part of the existing premises, or
• where the landlord intends to occupy themselves.

Depending on the grounds of opposition, various criteria must be met for a landlord to oppose a new lease successfully.

My landlord wants to redevelop the premises. Can they oppose a new lease?

Theoretically, yes.

Section 30 (1)(f)("Ground F") of the Act states that a landlord can oppose a lease renewal if "on the termination of the current tenancy, the landlord intends to demolish or reconstruct the premises comprised in the holding or a substantial part of those premises or to carry out substantial work of construction on the holding or part thereof and that he cannot reasonably do so without obtaining possession of the holding."

It is necessary to properly consider and seek professional advice on whether the landlord can establish that they intend to demolish or reconstruct a substantial part of the premises.

What steps should be taken upon receiving notice of Ground F opposition?

If you faced Ground F opposition, it is important to act quickly. It is advisable to:

• Obtain copies of all proposed plans, planning applications and supporting documentation from your landlord.
• Instruct a building surveyor to assess whether the proposed works genuinely require vacant possession.
• Engage a specialist commercial property solicitor with experience in lease renewal proceedings.
• Consider whether you might accept a lease of part of the premises unaffected by the proposed works.
• Assess your potential compensation entitlement should the opposition succeed.
• Review your lease terms for any existing landlord's rights of entry that might enable works without requiring vacant possession.

The earlier you take action, the stronger your position will be in any subsequent negotiations or court proceedings.

What points need to be considered when looking at Ground F?

You should think about the following:

• The entirety of the works to be carried out.
• The extent of the landlord's intention to carry out the works.
• Whether the landlord has reasonable prospects of carrying out the works.

What works does Ground F actually relate to?

It is necessary to break down the wording of Ground F to establish the various categories of works.

Ground F relates to demolition of the whole of the property that is occupied by the tenant, or demolition of a substantial part of the property that the tenant occupies, or it could be a reconstruction of the whole of those premises, or a reconstruction of a substantial part of the premises occupied by the tenant, or substantial works of construction to the whole property, or substantial works of construction to part of the property occupied by the tenant.

A well-advised tenant should obtain advice from a building surveyor and property lease dispute solicitor about the works that the landlord is proposing and whether they will be sufficient to rely on Ground F successfully.

What does the holding mean?

This means the part of the premises that the tenant occupies for business purposes. It may be the case that the landlord intends to undertake works to parts of the premises that the tenant does not occupy for its business, and these would not qualify as qualifying works under Ground F.

What does reconstruction mean?

This means work involving the structure of the premises and usually involves some form of destruction of what is already there and replacing it in a different form. Preliminary and finishing works should also be taken into account in this context, for example plastering works to a newly built wall.

What does reconstruction of a substantial part of the holding mean?

This means reconstructing a substantial part of the building that will be affected by the works. It will be a question of fact to be decided by the Court whether the works intended by the landlord are a reconstruction of a substantial part of the holding.

What does construction mean here?

This generally means creating something new, rather than simply altering something that already exists. If the tenant is obliged to carry out works under the lease, then those works will not qualify as works of construction for Ground F.

Does the landlord need to regain possession in order to carry out the works?

Ground F can only be satisfied if the landlord requires possession of the property to carry out their intended works. It is necessary in this context to consider whether the landlord already has rights reserved in the lease to enter the premises to do the works, whether the landlord can carry out the works without the limitations of any rights in the lease, and whether the tenant would be able to carry on its business at the premises after the works have been completed.

Many commercial leases contain provisions that allow landlords to enter and carry out work on the premises. However, such rights must be considered against the tenant's right to quiet enjoyment of the premises. The more disruptive the proposed works, the less likely it is that existing lease provisions will be sufficient to enable the landlord to proceed without obtaining vacant possession.

When does the landlord have to show they are going to carry out the works?

The landlord must demonstrate that it will commence the works at the end of the current tenancy. The end of the current tenancy could mean the date specified in a Landlord's Section 25 Notice, the date specified in a Tenant's Section 26 Request for a new tenancy, or, if Court proceedings are issued, the tenancy would end 3 months after the Court has made its final order.

It doesn't mean that the landlord has to be ready to start work on day 1, as long as the landlord can demonstrate that they will start work within a reasonable period after the end of the existing lease. Recent case law suggests this period may extend from 3 to 14 months depending on the complexity of the proposed development.

What intention does the landlord have to demonstrate?

The landlord must do more than merely state that it intends to demolish or reconstruct the premises. A Court would have to be satisfied that the landlord can show a firm and settled intention, and has a reasonable prospect of achieving that intention. The landlord must demonstrate a fixed intention to proceed and provide evidence that they have considered the issues that may need to be resolved, showing that there are few hurdles that need to be overcome. The more advanced the landlord's redevelopment plan is, the stronger a position the landlord will be in.

What might a landlord need to have to show a firm and settled intention?

A well-advised landlord would think about obtaining the following:

• Board minutes documenting its intention, if it's a company
• Planning permission for any scheme
• Plans and drawings
• Consents from any third parties that may be needed
• Building contract
• Finance and funding
• Vacant possession of any other part of the development site
• A business plan for future use

How does a landlord show a reasonable prospect of carrying out the development?

A landlord may be able to demonstrate a fixed intention to carry out the work, but it might fall short if it cannot show a clear path to implementing the development and if there are too many obstacles in its way.

A reasonable prospect is a real chance of being able to carry out the development and a course of action that a reasonable landlord would follow.

What are the typical costs and timeframes for Ground F proceedings?

Ground F disputes involve considerable expense and time. Typical costs include:

• Legal fees: £15,000-£50,000+ depending on the complexity of the case
• Expert witness fees for building surveyors and planning consultants: £5,000-£15,000
• Court fees and other disbursements: £2,000-£5,000
• Business disruption and opportunity costs

Proceedings typically take 12-18 months from commencement to trial, although urgent applications can sometimes be resolved more expeditiously. In the event of an unsuccessful challenge, you may become liable for the landlord's costs in addition to your own.

However, should you succeed in defeating the Ground F opposition, the landlord will typically be ordered to pay your reasonable legal costs.

What compensation is payable if Ground F succeeds?

Should your landlord successfully oppose your lease renewal on Ground F, you are entitled to statutory compensation under the Act. The quantum depends on the length of your occupation:

• Shorter occupation (less than 14 years): Compensation equivalent to the rateable value of the premises
• Longer occupation (14+ years): Compensation equivalent to twice the rateable value
• Additional compensation may be recoverable for:
• Removal and relocation expenses
• Loss of business goodwill
• Professional fees incurred in securing alternative premises
• Abortive costs should the landlord fail to proceed with the stated development

What can a tenant do to oppose Ground F?

A tenant could agree to include new terms in its new lease, or take a lease of part of the property, which would entitle the landlord to do the works.

Alternative strategies include:

• Challenging the adequacy of the landlord's intention or prospects of carrying out the works.
• Arguing that the proposed works do not require vacant possession.
• Demonstrating that the works do not qualify under the provisions of Ground F.
• Negotiating enhanced lease terms or additional compensation in lieu of opposition.
• Seeking an interim lease whilst planning or other matters are resolved.

Ground F compared with other grounds of opposition

It is worth understanding how Ground F differs from the other statutory grounds:

• Ground G (own occupation): Where the landlord requires the premises for occupation for business purposes - may be easier to establish but carries the same compensation provisions.
• Ground A (disrepair): Based upon tenant's breach of repairing obligations - no compensation is payable
• Ground E (uneconomic letting): Where landlord offers a lease of part of the premises only - has limited application

Ground F frequently overlaps with Ground G where a landlord asserts an intention to redevelop for their own subsequent occupation. The distinction lies in Ground F, which requires specific evidence of development intention and adequate funding arrangements.

Warning signs of a weak Ground F claim

Particular scrutiny should be applied where:

• Planning permission has not been obtained, and the proposals appear to face significant planning obstacles.
• Proper costings and funding arrangements have not been disclosed or appear inadequate.
• The proposed works could reasonably be undertaken whilst the tenant remains in occupation.
• The landlord has previously relied upon Ground F assertions to secure vacant possession without subsequently implementing genuine development.
• The development value appears marginal when compared with the rental income being foregone.

How does this all work in practice?

The recent County Court decision in Spirit Pub Company (Managed) London Ltd v Pridewell Properties (London) Limited in 2025 highlights the various aspects of a landlord's opposition, relying on Ground F, in practice.

The facts:

The tenant was attempting to renew its lease of a pub in South Woodford, London. The landlord opposed the renewal on Ground F and stated that it would carry out a residential conversion of the tenant's property, which would include works to the beer garden, the first and second floors, and the bar area of the ground floor. The works would include three new mews houses in the beer garden and a substantial reconstruction of the pub to provide six self-contained flats on the upper floors, with a retained pub at ground-floor level. In this case, the Court was concerned with several aspects of Ground F, as detailed below:

How soon must ground F works be started?

A landlord must demonstrate that, upon the expiration of the current tenancy, they will commence their proposed redevelopment works. Previous case law has shown that this period is a short time after the tenant's lease has ended, but the precise period is always a matter for the Judge to decide in each case. In previous cases, it has been held that 3 months would be uncontentious; however, if the work was not going to begin for a period of 12 months, then that would be too far removed from the end of the tenancy. In this case, based on expert evidence, the landlord's works were not scheduled to commence for between 10 and 14 months after the end of the tenancy. Although this was regarded as an exceptionally long period to count as a reasonable time, the Judge accepted that it was reasonable in this instance.

Is possession required by the landlord for its Ground F works?

The landlord must demonstrate that they could not reasonably carry out their works without obtaining possession of the holding. Here, the tenant's lease contained a right of entry for carrying out works, including a right to enter and remain on the premises with all necessary tools, appliances and materials for the purposes of repairing, altering or rebuilding any adjoining property or the premises. This wording granted the landlord substantial rights to carry out work on the premises. However, the Court took the view that any right to enter to carry out works on the premises must necessarily be interpreted in light of the landlord's obligation to allow the tenant quiet enjoyment of the property. In light of the knowledge that the tenant had been granted a lease to enable it to operate a pub, the Court ruled that the landlord's entry rights were insufficient. The Court further held that the landlord would require possession to carry out its scheme of works.

Is the landlord's subjective intention able to be realised?

To succeed with Ground F, a landlord has to have an intention genuinely held and capable of achievement, that they are going to carry out the works. Here, the Judge was satisfied that the landlord held a firm and settled intention to carry out the works. However, several hurdles in its way could render the subjective intention incapable of being brought to fruition.

There were, for example, unknown restrictive covenants affecting the site, and secondly, the local planning authority had provided pre-application advice that an objection might be raised in principle to an application to demolish the existing pub building, which was a public house in a very prominent location in the middle of town.

There was also a question over funding for the works, and this was the ground on which the landlord failed. The Judge felt that the landlord's lender would be prepared to lend sufficient money to carry out the works. However, the bank had indicated that it would require the directors and shareholders of the landlord company to provide personal guarantees, and no evidence had been presented regarding the personal finances of any of those parties or their ability to provide satisfactory guarantees for funding. This led to a failure to establish that the landlord could succeed, relying on Ground F.

Practical lessons from the Spirit Pub case

This decision illustrates several important principles for tenants facing Ground F opposition:

• Even substantial development proposals may fail where funding arrangements prove inadequate.
• Planning difficulties, including at the pre-application stage, can fatally undermine a landlord's case.
• The Court will examine the practical feasibility of development proposals, not merely the stated intention.
• Undisclosed title issues, such as restrictive covenants, may prove fatal to Ground F's reliance.

When settlement may be preferable to litigation

Commercial considerations may favour negotiated resolution rather than contested proceedings where:

• The landlord has assembled strong evidence of both intention and funding.
• Your business circumstances make the compensation valuable
• Suitable alternative premises have been identified.
• The costs of litigation would exceed the commercial benefit of retaining the existing premises.
• The landlord offers significantly enhanced compensation or extended lease terms.

Alternative dispute resolution

Before commencing costly court proceedings, consideration should be given to:

• Professional mediation: Often achieves resolution more quickly and cost-effectively than litigation
• Expert determination: Provides a binding decision from a specialist practitioner
• Commercial negotiation: Direct discussions between legal representatives
• Arbitration: Formal but more expeditious than court proceedings

Many lease renewal disputes are resolved through these processes, thereby avoiding the uncertainty and expense of trial.

When professional advice becomes essential

Specialist legal advice should be taken immediately upon:

• Receipt of a Section 25 notice opposing renewal on any ground
• Any indication from your landlord that renewal may be opposed
• Consideration of serving a Section 26 request
• Approaching expiry of your lease within the next 12 months

Ground F opposition should not be attempted without experienced legal representation. The legal framework is complex, procedural requirements are strict, and the consequences of inadequate preparation can prove catastrophic for your business.