Wyldecrest Parks (Management) Ltd v North Northamptonshire Council (PARK HOMES - SITE LICENSING - licence condition requiring licensing authority's consent to any material change in site layout - conditions regulating access and parking - whether conditions unduly burdensome - FTT permitting local authority to amend licence condition during appeal - whether a procedural irregularity - ss. 5, 7, 9, Caravan Sites and Control of Development Act 1960) [2026] UKUT 52 (LC) (06 February 2026)

Executive summary

The Upper Tribunal (Lands Chamber) considered an appeal by Wyldecrest Parks (Management) Ltd against North Northamptonshire Council over three site-licence conditions for Wilby Caravan Park under the Caravan Sites and Control of Development Act 1960. It allowed the appeal in part, addressing whether a consent-to-layout-change condition, an emergency-access condition, and a parking-ratio condition were unduly burdensome, and whether the First-tier Tribunal had committed a procedural irregularity by modifying a condition during the appeal.

Key points

• Parties: Wyldecrest Parks (Management) Ltd v North Northamptonshire Council; site licence for Wilby Caravan Park, Northamptonshire.
• Issue: condition 6 required prior written consent for any material change in site layout; Wyldecrest argued this was unduly burdensome.
• Issue: condition 11 regulated emergency-vehicle access; condition 34 imposed parking spaces at a fixed ratio of one per caravan plus one per five caravans.
• The FTT had added wording to condition 6 to create a 28-day determination period and treat non-response/refusal as a refusal for appeal purposes.
• The Tribunal decision is framed under ss. 5, 7 and 9 of the 1960 Act and refers to the Model Standards 2008; no sanctions/export-control issue is identified in the source text.
• Holding stated in the report: appeal allowed in part.

Why it matters

This is a site-licensing control case, not a sanctions case, but it is relevant to sovereign-risk and regulatory-risk analysis because it shows how local authorities can impose and defend operational constraints on land use through licensing powers. The decision also matters for compliance strategy because it tests the boundary between lawful licence conditions and conditions that may be struck down as unduly burdensome or procedurally irregular.

Implications

For regulated operators, the case underscores that licensing authorities can use site-licence conditions to control layout, access, and parking, but those conditions remain appealable where they go beyond what is necessary or become procedurally defective. For litigation strategy, the FTT’s attempt to rework a condition during appeal and to create an appeal trigger for non-response highlights the need to challenge both the substance of licence terms and the tribunal’s procedural handling of amendments.