The criminality of squatting on a residential Property and Adverse Possession:
‘is s144 Legal Aid, Sentencing and Punishment of Offenders Act (LASPOA) still
relevant?’
The problem of squatting in a residential property is not by choice. The phenomenon
is a reflection of the realities in society and an indication of the disconnection
between authorities and the working class. The solution is not a new law (s144
LASPOA) to criminalise squatters but instead a call for practical, human-centred
policies to address the problem of inadequate housing and the need for socio-
economic re-alignment.
Introduction
The introduction of section 144(1) LASPOA 2012 1 which criminalises squatting in
residential property was welcomed by a section of the public in England and Wales,
especially homeowners as the law that could reduce squatting in residential settings,
if not eliminate them. It was a general belief among homeowners that the lack of
adequate, punitive, criminal legislative framework exposed them to what they
believed to be the menace of squatters. The new law appeared to offer hope and
assurance to homeowners. The campaigners of the law appeared vindicated by the
conviction and custodian sentencing of the first-ever person under s144(1) 2 for
twelve weeks in prison. The Ministry of Justice (MoJ) hailed the law as enabling
‘quick and decisive action to protect homeowners 3. However, the new law brought
difficulties to the homeless community in its wake.
Data collected by Squatters Action for Secure Homes (SQUASH), a charity
organisation indicated that within a space of three years from 2012 to 2015, there were at
least 738 arrests out of which 326 were prosecuted and over 60 squatters were
convicted of the offence under s144 4. The rate of arrest and convictions of
squatters unveiled deep-seated socio-economic problems that had blighted
the British society but, to a large extent, had either gone unnoticed by
1
Legal Aid, Sentencing and Punishment of Offenders Act 2012 (legislation.gov.uk) (accessed 3rd April
2022)
2
London squatter first to be jailed under new law - BBC News (accessed 3rd April 2022)
3
Ibid
4
SQUASH REPORT: Squatting Statistics 2015 | Advisory Service for Squatters (accessed
3rd April 2022)
politicians and policymakers or it’s just been ignored. According to
information gathered by SQUASH, in the process leading to the passing of the
law, the government consultation indicated that 96% of respondents opposed
the law, and expressed strong reservations that the law would impact the
vulnerable in society, but they were ignored 5. In the Parliamentary debates, the
campaigners against squatters sought to decouple homelessness from
squatting by arguing that homelessness is not the cause of squatting. It was
further argued that ‘not a single squatter was homeless because they have
chosen to occupy a vacant property, they had actively removed themselves
from the categories of ‘‘homeless’’ and were now ‘‘squatters. 6’’ This position
by the government was rejected by opponents of the law, who have always
insisted that the correlation between homelessness and squatting is
irrefutable, and thus the section is unjust and unnecessary because the
Criminal Law Act 1977 was adequate and there was no need for a new criminal
law.
The similarity is drawn between the provisions of s144 LASPOA and that of the
Criminal Law Act 1977, especially s7. Section 144 (1) of LASPOA provides a
squatter as an individual who has trespassed on a residential property and
intends to live there7. This is compared to section 7 of the Criminal Law Act which
also provides that; an offence is committed by a person who is on any premises as a
trespasser and fails to leave on being required to do so, and s76 also makes it an
offence for a trespasser to fail to leave the property within 24 hours of service of an
interim possession order or return to the property within a year of such an order
being served8. It appeared ss7 and 76 were adequate to criminalise squatting if that
was what the government wanted.
The sections as having been stated above clearly demonstrate that the existing laws
remain adequate for protecting residential properties.
However, campaigners called for a punitive and specific law against squatting on a
residential property. A Member of Parliament, Mike Weatherley and his
campaigners managed to secure the passing of s144(1) of the Legal Aid,
5
Ibid
6
1007728.pdf (oapen.org)
7
Squatting in residential buildings | Westlaw UK (accessed 3rd April 2022)
8
Criminal Law Act 1977 (legislation.gov.uk) (accessed 3rd April 2022)
Sentencing and Punishment of Offenders Act in Parliament. Subsequent analysis of
s144 reveals a much bigger cost to the taxpayer of its implementation and
execution. The research took into account the cost of evicting squatters or
homeless people, the arrest and prosecution and subsequent possible
rehabilitation, and rehousing of former squatters, all paid by housing benefits 9.
Impact analysis by SQUASH into the criminalisation of homeless people
squatting in residential properties took into consideration the housing crisis,
empty properties and homelessness to provide a context for a cogent analysis
of the after-effect of LASPOA s14410. The findings did not surprise anybody as
the concerns raised during the government consultation manifested in the
number of vulnerable people and homeless people disproportionately affected
as previously feared and there was no indication that squatters forcibly
dislodged anybody from their homes. There were no proper records from the
Local Authorities to indicate the number of homeless people squatting under
their jurisdiction.11
Campaign for the rights of squatters
The argument in favour of squatting which could potentially lead to adverse
possession has always been an argument against homelessness as opposed
to an effort to take people’s homes by force. The need for housing was
considered a fundamental right of every citizen and people who squat are
deserving people. The lack of adequate accommodation and the means to
secure accommodation as a result of socio-economic problems,
consequences of economic downturn or economic mismanagement had
forced many working-class families into poverty. These occasionally result in
family breaks ups causing people to lose their homes and properties. The
consequences of this homelessness automatically translate to rough sleeping
and squatting.
The family breakups and other socio-economic pressures creating
homelessness which result in squatting undermine article 8(1) of the Human
9
SQUASH REPORT: Squatting Statistics 2015 | Advisory Service for Squatters (accessed 3rd April
2022)
10
Ibid
11
Ibid
Rights Act 1998, which provides for the right to private and family life, for
home and correspondence12. It has never been proven that homelessness
which leads to squatting is a matter of choice. Squatting has always been
occasioned, predominantly by adversities and imbalance or unfair distribution
of economic opportunities. In his article titled ‘Squatting: The Fight for Decent
Shelter’, John Marsland explained that ‘at the core of squatting was an implicit
as well as explicit confrontation with a social and political force that kept
homes empty whilst millions are homeless or have unfit and inadequate
homes13’.
Current data published by the Ministry of Housing, Communities and Local
Government (MHCLG) for 2019 empty properties alone in England stood at
648,114 up 2.2% from the previous years. As many as 225, 845 were classed as
long-term empty properties.14
Campaign against the rights of squatters – Mike Weatherley MP
The campaign for the rights of squatters over the years, which gained some
minimal success was opposed by some people. One of the most prominent
people who launched the campaign against squatters was the former
Conservative MP for Hove Mr Mike Weatherley. He conducted his campaign
against squatters in a way that appeared to resonate with homeowners and the
government. Despite his subjective motive, Weatherley redefined who a
squatter was, or supposed to be in his opinion, and then pointed accusing
fingers at the middle-class. Mr Weatherley said;
‘Some of those who are homeless have indeed squatted but this does not
make them squatters. A typical squatter is a middle-class, web-savvy, legally-
minded, university-educated and, most importantly, society-hating. They are
very often extremely intimidating and violent. They are political extremists
whose vision for society is a dysfunctional medieval wasteland without
property rights, where an Englishman’s home is no longer his castle’ 15. The
message directly appealed to the conscience of homeowners in England and
12
Human Rights Act 1998 (legislation.gov.uk) (accessed 7th April, 2022)
13
Squatting: The Fight for Decent Shelter, 1970s–1980s | Britain and the World (euppublishing.com) (accessed
7th April, 2022)
14
Empty housing (England) - House of Commons Library (parliament.uk) (accessed 8th April 2022)
15
1007728.pdf (oapen.org) (accessed 9th April 2022)
Wales and resonated well among a vast number of homeowners and, even
some politicians of all persuasions and in Parliament across the aisle. The
Shadow Justice Secretary, Andrew Slaughter gave a summary view about the
sort of people he thinks squats in residential properties as mentally ill and
drug addicts. He stated that ‘it is also right to say that there are, ‘lifestyle
squatters’ –people who are part of the something-for-nothing society. We
disagree with that, and we support the criminalisation of their activities.
However, many squatters are homeless. and often have severe mental health
and addiction problems.16 The campaign attracted the interest of the media and
a great number of news stories which portrayed squatters as violent invaders,
‘parasites,’ enemies to the values of society, and it portrayed foreigners as
people who have come to Britain to exploit its alleged ‘soft touch’ to crime 17.
These foreign criminals who were, supposed, to be taken over were hugely
exaggerated and overhyped by the Weatherly group and the media. The
message against squatters was intense to the extent that they were described
as people who ‘‘deprive legitimate occupants of the use of their properties,’’ 18
It is important to note that the campaign to have squatting criminalise was
limited to residential properties. Squatting in commercial properties, however,
remains a civil matter. Pye v Graham. The implementation of s144 LASPOA in
2012 changed the way squatting is prosecuted from civil to criminal
prosecution.
When section144 LASPOA came into force, it became almost impossible for
squatters in a residential property to assert their rights. This is because by
doing so they will be committing a criminal offence and the police may invoke
s17 of the Police and Criminal Evidence Act 1984 to enter and arrest them. 19
The rights to family life, as enshrined in Article 8(1) of the European
Convention of Human Rights, which provides that ‘everyone has the right to
respect for his private and family life, his home and his correspondence’
became a matter of concern for campaigners of squatters rights. Campaigners
against squatting argued about what they perceived as the apparent breach of
16
Ibid
17
Ibid
18
Ibid
19
Squatting in residential buildings | Westlaw UK (accessed 12th April 2022)
Article 1, Protocol 1 of the European Convention on Human Rights which
caters for the protection of properties.
Article 1, Protocol 1 guarantees the peaceful enjoyment of individuals’
possessions, which can only be deprived of in the public interest subject to the
conditions provided for by law. The preceding provisions shall not, however, impair the
State’s right to enforce such laws as it deems necessary to control the use of the property. 20
The introduction of s144 of LASPOA was not the only law that made squatting difficult and
criminal, but the new Land Registration Act of 2002 made it equally impossible for squatters
to adversely possess properties, even if they had satisfied the new limitation period of 10
years.
Adverse possession
The basis for adverse possession was the ‘longer user’ principles, however,
the LRA 2002 fundamentally changed the principle of automatic adverse
possession of property where the title of the registered property owner is
extinguished after attaining the limitation period of 12 years of sustained
possession under LRA 192521 in addition to the satisfaction of various
common law elements to lay claim of a property using an adverse possession.
Elements such as; factual possession 22 and the possession must be exclusive
in the recent case of Toor. 23 The possession of the property must be without
the concern of the owner, or it must be adverse 24, and a demonstration of
intention to possess.25
On the surface of the requirements, it appears squatters largely satisfy these
requirements, of course in addition to the limitation period. Every time
squatters would be in factual possession of the residential properties, they
exclude everybody especially the title owner, to demonstrate their intention to
possess the properties and discontinuous possession of the property by the
owner. However, schedule 6 paragraph 1 of LRA 2002, sets out a new regime
20
Article 1 of the First Protocol: Protection of property | Equality and Human Rights Commission
(equalityhumanrights.com) (accessed 14th April 2022)
21
Chris Bevan, Property Law
22
Pye v Graham (2002)
23
British Waterways Board v Toor (2006)
24
Buckinghamshire CC v Moran (1990)
25
Pye v Graham (2002)
for adverse possession in the fact that the limitation period is not only
changed from 12 years of unregistered land under the Limitation Act 1980 to
10 years for registered land but more importantly and which, seem to go to the
root of the principles of adverse possession is the fact that the registered
owner of the property is notified by the Land Registrar under Schedule 6,
Paragraph 2 of the application to register the land to extinguish his title and
adversely possess his property.
He is given 2 years to act, unless the titleholder failed to act, which is unlikely,
the squatter would have the title registered to him. 26 The combined application
of the LASPOA 2012 s.144 and Schedule 6 of LRA 2002, led to the denier of Mr
Best in claiming adverse possession of the residential property.
Best v Chief Land Registrar27
The fact of the case has it that; the property in dispute was registered in the
name of Doris May Curtis at 35 Church Road. The claimant, Mr Best applied to
register the title to the property based on adverse possession, having
completed the limitation period of ten years as required by Schedule 6
paragraph1 LRA 200228. The claimant, Mr Best did several repair works on the
property and the garden to make it his own or permanent residence. There was
no dispute and no question asked at all the time he was working on the
property. He treated the property as his own from 2001 until he moved in in
2012 January. Mr Best claimed he occupied the property without anyone’s
consent. He admitted he was a trespasser on the property. 29
The Chief Land Registrar denied Mr Best the registration of the property on the
basis that s144 LASPOA prevented him from relying on the said period for
adverse possession, which involved a criminal offence. The Chief Land
Registrar also noted that Schedule 6 of the LRA 2002 required that no part of
the applicant’s possession within the limitation period of ten years should
26
Chris Bevan, Property Law
27
Search Results | advanced: (TI(r on the application of best v chief land registrar)) | Westlaw UK (accessed
14th April 2022)
28
Ibid
29
Ibid
constitute a criminal offence.30 Therefore, the application was declared
substantially defective, not by the court, but by the Chief Land Registrar. Mr
Best appealed.
Grounds of appeal
Mr Best raised four grounds of appeal. In summary, he contended that s144
LASPOA has no effect on the operations of LRA 2002, so the Chief Land
Registrar erred in law in refusing the registration of the title. It was argued that
s144 only criminalises squatters who are in actual occupation or ‘‘living in’’
the residential property and does not affect other physical acts or works that
Mr Best did on the property, for example, fixing the windows and securing the
doors, which were capable of leading to adverse possession and sufficient
enough for him to apply for registration, and he never lost his intention to
possess the property and also contended that s144 LASPOA should be read in
a way to avoid conflict with Article 8 ECHR or Article 1 of Protocol 1 to the
ECHR.31 This means s144 should be read in a way that would not prevent the
application to register title or prevent adverse possession.
Mr Best argued that the 2012 Act should be interpreted to exclude or not apply
to abandoned properties or permit 10 years of adverse possession. Finally, Mr
Best argued that should all else failed s144 should be declared incompatible
with ECHR on grounds of criminalising a residence in his home. 32
Does s144 LASPOA affect adverse possession under the LRA 2002? 33
Mr Best argued that the very concept of adverse possession leading to the
right to be registered as the proprietor of land means the law in some
circumstances, for public interest permits someone to rely on a wrongful,
tortious, act to adversely possess a property. He further contended that the
purpose of s144 was not to affect the acquisition of title by adverse
possession. He also said the English legal system for good reason had
30
Ibid
31
Ibid
32
Ibid
33
Ibid
developed a means whereby long-established peaceable possession of the
land conferred title.34 Mr Best warned that the position taken by the Chief Land
Registrar on LASPOA is capable of precluding the acquisition of title to residential
property, which has been occupied for decades or centuries of such possession.
He argued that the essence of the limitation is not to allow reliance on the
respondent’s own wrong alone but also on the lack of action by a property owner to
assert his rights in the face of the Respondent’s wrong over a long time. He said s98
of Act 2002 envisaged that even a court order, if unenforced for two years, could in
certain circumstances not prevent an applicant’s disobedience founding part of the
period relied on in his application. 35
In his response, the Chief Land Registrar submitted that the 2002 Act should be
construed by reference to the general principle that no judicial system should
enforce, rights which derive from the criminal acts of the person who seeks to rely on
them. He further pointed out that as of 1 st September 20012, the Claimant’s living in
the property had become a crime, and that he could not rely on his crime to assert
the right to registration as an owner because the Act applied as soon as entry had
been obtained as a trespasser and criminal trespass was not an accepted foundation
for adverse possession.36 He further contended that no provision of the 2012 Act
suggested that s144 was not to affect the operation of Schedule 6 to the 2002 Act.
The Respondent argued that, as a matter of construction, the principle of public
policy prevented continued reliance on ‘‘living in’’ the building to find the application
for registration and that there was no reason for sympathy to squatters, and the 2002
Act was not designed to advance the squatters position over registered owners.
In conclusion; The Respondent contended that ‘‘adverse possession’’ in
Schedule 6 paragraph 1 to the 2002 Act, and s15 of the Limitation Act 1980,
means possession which is tortious and unlawful, but not an unlawful
possession, which by itself it is a criminal offence. He further explained that
‘‘adverse possession’’ is a common law concept and not statutory in origin,
but only adopted by the statute.37
34
Ibid
35
Ibid
36
Ibid
37
Ibid
In the ruling, the court held that the fact that certain forms of adverse
possession are tortious and criminal, they never remove the civil effect of the
unlawful possession. If that argument is to be sustained as Mr Best invited the
court to believe then there is no reason for the Act of 2012 to be given a
different effect. In that respect, Mr Best would succeed because criminal
possession was adverse in the common law concept adopted by statute. 38 The
court, however, observed that no case was cited in support of the argument.
The court accepted the Respondent’s submission on the principle that rights
should not be derived from criminal acts. The court also acknowledged the
authorities cited by the Respondent in support of his argument. In the case of
Cleaver39 in which the husband took out a policy of life assurance for the
benefit of his wife, who then murdered him. The trust in favour of the wife was
not enforced because of her crime as a matter of public policy, and the recent
case of Lewisham40 and that of Tinsley41 in which the House of Lords held that
the Respondent’s claim to interest was not barred by the fact that the property
was purchased to carry out benefit fraud. In that case, the Lords rejected the
principles of an ‘‘affront to public conscience’’ test in determining the extent to
which rights created by or for illegal transactions should be recognised. 42
In summarising his conclusion; Lord Jauncey held that illegality could not be
relied on to advance the Respondent’s claim and it cannot be a proof of his
defence. Judge Brown concluded by saying; ‘property can pass under a
contract which is illegal and therefore would have been enforceable as a
contract; a plaintiff can enforce his property rights acquired if he does not
need to rely on the illegal contract in enforcing his claim to property rights and
it does not matter if a legal title is acquired under illegality. 43
38
Ibid
39
Cleaver v Mutual Reserve Fund Life Association [1892]
40
Lewisham BC v Malcolm [2007]
41
Tinsley v Milligan [1994]
42
Search Results | advanced: (TI(r on the application of best v chief land registrar)) | Westlaw UK (accessed
15th April 2022)
43
Ibid
Thus, the court held that for the reasons given, the Chief Land Registrar’s
decision was founded on an error of law as to the effect of s144 LASPOA on
adverse possession.
The effect of other acts of adverse possession
The case of Pye44 was an authority for adverse possession, and in that case,
two elements in adverse possession were noted. It was observed that to
establish adverse possession, the individual must be in actual possession of
the property backed by an intention to possess the same. In this regard, actual
possession is said to have been assumed when a squatter assumes single and
exclusive possession, dealing with the property as an occupying owner might
have been expected to deal with it with a reasonable degree of control. The
intention is said to be when a squatter appeared to exclude the world at large
including the owner with the title. 45 Mr Best, thus argued that he had
undertaken acts of adverse possession other than ‘‘living in’’ the property, and
the Respondent had failed to clarify what acts of adverse possession, if any,
other than occupation, he regarded as criminal by LASPOA 46.
Article 8 and Article 1 Protocol 1 ECHR
Mr Best submitted that s144 breached his Article 8 rights by making it
impossible for him to exercise his rights in a property where he had lived for
so many years a criminal offence. He contended that s144 must be treated in a
way that does not affect adverse possession through ‘‘living in’’ a residential
property. Thus, it should not be applied to an abandoned property. He further
argued that Schedule 6, alternatively, should be read in a way that permits 10
years of adverse possession before 1 st September 2012.47 Mr Best further
argued that s144 was not ‘by law’’ for Article 8 nor a condition ‘provided for by
44
Pye v Graham [2002]
45
Search Results | advanced: (TI(r on the application of best v chief land registrar)) | Westlaw UK (15th April
2022)
46
Ibid
47
Ibid
law’’ for Article 1 Protocol 1, because it was arbitrary, and lacked the
requisites of ‘law’’ for the Articles above48 as shown in Barnes49
Legal Background & Summary of Best v Chief Land Registrar.
Section 58 of the Land Registration Act 2002 provides that the Chief Land Registrar
must conclusively rectify any title mistakes, and subsection (1) provides that, ‘‘ If on
the entry of a person in the register as the proprietor of a legal estate, the legal
estate would not otherwise be vested in him, it shall be deemed to be vested in him
as a result of the registration’’. 50 It is thus the register which guaranteed a title to
registered land and not the possession of the land. in any case, when an application
is made to register a title by adverse possession, Schedule 6 paragraph 2 of Act
2002 demands that the registered owner be notified for the appropriate rectification
measures to be taken, and unless the registered owner failed to act within two years,
the title will be registered for adverse possession. Paragraph 6 also provides Mr Best
with another opportunity to re-apply if he is still in adverse possession of the property
for two years after the initial rejection of his application. 51 The logic behind the Act of
2002 was, either to halt or frustrate squatters like Mr Best from acquiring properties
by adverse possession.
The joint paper which became the source of Act 2002 stated that the essence of title
registration is to protect the registered proprietor of land against adverse possession,
and s144 essentially criminalises squatting in residential property. However, the case
of Best in the High Court Held that ‘where a squatter claimed title to a residential
property based on adverse possession, the fact that part of his occupation
constituted a criminal offence under s144 LASPOA, that should not prevent his
conduct from qualifying as relevant adverse possession for the Land Registration Act
2002 Sch.6. The criminalisation of squatting did not mean that granting title to a
squatter in such circumstances amounts to him benefiting from his criminal
conduct.52 Thus, the application however succeeds, and the decision by the Chief
48
Ibid
49
Barnes v Eastenders & Cash Plc [2012]
50
Land Registration Act 2002 (legislation.gov.uk) (accessed 15th April 2022)
51
Search Results | advanced: (TI(r on the application of best v chief land registrar)) | Westlaw UK (accessed
16th April 2022)
52
Search Results | advanced: (TI(best v chief land registrar)) | Westlaw UK (accessed 18th April 2022)
Land Registrar is quashed. Mr Best’s application has to proceed through to the next
stage in Schedule 6 of Act 2002.53
John Locke’s 2nd Treatise of Government.
The acquisition of private property is central to John Locke’s theory on property in
the second treatise of government. The concept of adverse possession appears to
reflect certain parts of the theory, and at the same time, appeared to be the cause of
private acquisition of uncontrolled wealth and property to the detriment of the vast
majority of people.54
In advancing his theory of private acquisition, Locke wrote that ‘‘since free person
owns himself; he owns the labour that emanates from his body. When he gathers the
land, the labour in him is mixed or incorporated into the land, and that means he has
a greater right to that property than anyone else and it becomes his property’’. John
Locke further explained that the acquired property is ‘removed from the common’
and every man is excluded.
This concept has formed the basis of modern capitalism, and private property
acquisition has no limit. This has led to only a few in society controlling enormous
wealth and property to the detriment of the majority. As indicated above, there are a
vast amount of empty properties majority-owned by private individuals, yet the
number of homeless people keeps increasing. The only way out for these
unfortunate people is to go in and occupy those empty residential properties as
squatters.
However, John Locke recognises the limitation of the land and acknowledged that
some people may acquire more than what they needed and the surplus may go
waste whiles others may be in need. He addressed this by saying; ‘‘for he that
53
Search Results | advanced: (TI(r on the application of best v chief land registrar)) | Westlaw UK (accessed
18th April 2022)
54
The first and second treatises of government
leaves as much as another can make use of does as good as take nothing at all, and
the surplus would be taken away55’’.
Squatters occupy empty properties, most of the time abandoned residential
properties, which may be considered surplus, and this can be appropriated by
adverse possession. Campaigners against squatters, who were the promoters and
supporters of s144 of Act 2012 appear to approve of the first part of John Locke’s
property theory on the mode of private property acquisition but disapprove of the
second part of taking away the excess properties.
Conclusion and Recommendation
Considering the dispute between Best and the Chief Land Registrar (CLR), the
arguments raised by the CLR were his interpretation of s144 LASPOA. Legal
arguments from Best and the decision arrived by the court rightly concluded that the
CLR acted unlawfully. This demonstrates how s144 had been used to trample on the
rights of squatters.
It is the view of this project that s144 of LASPOA conflicts with Article 8 of ECHR.
The law fails to appreciate the gap between the rich and poor in capitalist modern
Britain which has occasioned socio-economic imbalance in the society. The law
appears to hunt down squatters whose only fault is the difficulty they face in today’s
Capitalist world, and the government’s inability to provide enough houses for people
who genuinely needed them.
Section 144 LASPOA needed to be repealed, because it only serve as a tool for the
rich and powerful in society to acquire a vast amount of properties as a way of
hidden unexplained wealth as the British government acknowledged.
The 10 years limitation period under the Land Registration Act 2002 for the
registration of title for adverse possession for registered land is subject to the CLR
notifying the paper title-holder and the two years for the title-holder to respond. This
provision is already a major hindrance to adverse possession
Though the call for the repeal of s144 LASPOA which was submitted to Parliament
on the 19th of March 2020, urging Parliament to repeal the law in light of the current
global circumstances has been rejected 56, it remains an important call for the
55
Ibid
56
Repeal 2012 section 144 LASPO, allow residential squatting. - Petitions (parliament.uk) (accessed 22nd April
2022)
government to listen and it is recommended that the government consider the
request and repeal the law.
Bibliography
Lock, L, The First and Second Treatise of Government (Amazon, 2019)
Stroud, A, Making Sense of Land Law (5th edn, Macmillan Education Palgrave, 2018)
Mackenzie, J and Nair, A, Land Law (18th edn, Oxford University Press,2020)
