By Tasmin Sarai

Trainee Solicitor

Commercial Property

25 February 2026

Article Blog News

The Landlord and Tenant Act 1954 (the 1954 Act) remains a significant aspect in commercial leases.

Recent developments, such as Sainsbury’s Supermarkets Ltd v Medley Assets Ltd and S Franses Ltd v The Cavendish Hotel (London) Ltd, have clarified the position on opposing a renewal lease under ground (f) of the 1954 Act where redevelopment is contemplated. This permits a landlord to oppose a renewal lease under the 1954 Act where they intend to redevelop the property that is being leased. This includes plans to demolish, reconstruct, or carry out substantial works which cannot reasonably be undertaken without obtaining possession of the demised property.

Following these developments, this article explores the practical considerations for landlords granting leases protected by the 1954 Act who wish to oppose on ground (f).

The context

Commercial tenants may benefit from “security of tenure” under the 1954 Act. This means that when the contractual term of the lease expires, the tenancy continues automatically and the tenant has the right to apply for a new lease, unless the landlord can successfully rely on one of the statutory grounds of opposition.

It is common for leases to be contracted out of the 1954 Act by agreement prior to completion. Contracting out removes security of tenure and gives landlords greater certainty and control over future possession.

Where a lease is not contracted out, it will benefit from statutory protection. Although this allows the tenant to remain in occupation after the contractual expiry, a landlord may oppose renewal if it can establish one of the statutory grounds set out in the 1954 Act.

There are a number of grounds; some relate to tenant default, such as breach of covenants, and others relate to the landlord’s intention. This article focuses on ground (f) which relates to the latter.

Redevelopment can create tension between landlord and tenant interests. However, with careful planning and structuring, disputes can often be avoided.

Practical Considerations for Landlords

Timely planning of redevelopment

A landlord seeking to rely on ground (f) must demonstrate a firm and settled intention to carry out the proposed works, together with a reasonable prospect of implementing them.

Whilst the intention for redevelopment must be proved at the time of any Court hearing, it should be considered in advance of lease expiry. Waiting until a tenant triggers the renewal process can significantly narrow strategic options.

Landlords should ask:

• Is redevelopment genuinely intended?
• Is the intention to proceed fixed?
• What issues may arise and how these will be resolved?

Evidence

Whilst a dispute may not become contentious, landlords should assume that any redevelopment proposals may be scrutinised.

Landlords should evidence the redevelopment plans, including:

• Securing planning permission (or progressing towards this).
• Obtain and/or evidencing funding.
• Getting the relevant approvals.
• Internal approval such as documented board minutes and resolutions with project timelines

Well-developed and properly documented plans place landlords in a stronger position, whether negotiating or opposing renewal.

Extent of Occupation

Ground (f) relates to redevelopment of the “holding”. This has been defined and interpreted to mean parts of the premises that the tenant occupies. It does not include the areas not occupied by a tenant, even if it is part of the demised premises. This means that if a landlords development plans do not involve the area the tenant occupies, the landlord will not be able to rely on ground (f).

This is an important consideration as a tenant may intentionally reduce their occupation to a smaller part to defeat an opposition on ground (f) as in the aforementioned Medley case.

Landlords should regularly review which pats of the property are actively occupied, and how the planned works would interact with this occupation.

Consider Alternatives to Opposition

Whilst a landlord may have a genuine intention to redevelop, an absolute refusal to renewing a lease is not the only option.

Landlords may consider:

• Granting a short-term lease whilst planning for the redevelopment progresses.
• Incorporating break clauses into a lease to allow for the possibility of ending a lease earlier if or when the redevelopment takes place.
• Granting a lease of part if the works do not require the whole demise.

A flexible approach can safeguard redevelopment plans and avoid disputes.

However, if plans cannot take place with tenant occupation, landlords may consider opposing a renewal lease on another statutory ground which could clearly be established. For example, the tenant fault grounds (grounds (a) to (c)), if proved, are likely to be stronger arguments for opposition.

Looking Ahead

Recent cases have highlighted the technical complexity surrounding opposing a renewal lease on ground (f) under the 1954 Act and the practical considerations landlords should take. Early legal advice can avoid potential conflicts, ensuring redevelopment plans can take place with minimal disruption and risk.

If you are a landlord wanting tailored advice on opposing a renewal lease under the 1954 Act, please contact our Commercial Property team. We can give advice to ensure that your position as a landlord is protected.

Disclaimer: General Information Provided Only

Please note that the contents of this article are intended solely for general information purposes and should not be considered as legal advice. We cannot be held responsible for any loss resulting from actions or inactions taken based on this article.