Mineral extraction during agricultural development

The Court of Appeal has made an important decision concerning the need for planning permission when agricultural development involves the removal of gravel and other minerals. The verdict implies that the scope of permitted development for agricultural activities under the General Development Order (GDO) is not as extensive as might once have been thought.

In West Bowers Farm Products v Essex County Council (Mineral Planning 24, September 1985), the applicants had wished to construct a large reservoir for agricultural irrigation purposes, a type of development which would automatically be granted planning permission under Class IV of the GDO 1977. At issue was whether the extraction of gravel which was necessarily involved was a further development for the working of minerals for which pl

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