Case Study
Park Homes Site in Dorset

Confirmed that a former naturist site can be used for residential mobile homes

A Section 192 application for a Certificate of Lawfulness of Proposed Use for permanent residential occupation of 45 caravans was granted at appeal.

The change of use of the naturist site to a park home site was found not to need planning permission. The Inspector concluded that the original description that referred to naturists and holiday use did not constrain the use of the site and original permission was effectively for a caravan and camping site.

The Inspector found that the 2003 planning permission was implemented and permitted the use of the land as a caravan and camping site.  The terms “Holiday” and “Naturists” he determined ‘are not of functional significance and are permissive, rather than restrictive, of the lawful use.  The only relevant condition that controlled the use of the land was condition 2 of the 2003 planning permission, but it merely restricted the number of caravans to no more than 45, rather than the use to which those caravans are actually put’. 

The permanent residential occupation of 45 caravans (which includes mobile homes) at the site would therefore not amount to the making of a material change in the use of the land that would require planning permission.