Ratio Decidendi
Only a person with a proprietary interest in land can sue in private nuisance. Interference with television reception by a building is not actionable in nuisance.
ข้อเท็จจริง
Residents near Canary Wharf Tower complained that the building interfered with their television reception. Some claimants were licensees without proprietary interests.
สรุปคำพิพากษา
The House of Lords held that only those with proprietary interests could sue in private nuisance — mere occupiers or licensees could not. Furthermore, the erection of a building that blocks TV signals is analogous to blocking a view, which is not actionable.
คำกล่าวสำคัญ
"An action in private nuisance will only lie at the suit of a person who has a right to the land affected."
— Lord Goff
การอ้างอิงภายหลัง
Leading authority on standing in private nuisance and the non-actionability of interference with TV signals.