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General Boundaries, Specific Problems: Handy Cross v Vanni

Where exactly is the boundary, and what happens when the title plan doesn’t give a clear answer?


In this Newsflash episode, Lizzie Collin is joined by Richard Snape to dissect the High Court’s decision in Handy Cross Dev Co Ltd v Vanni Properties Ltd [2026] a development-site boundary dispute based on an imprecise title plan.


After an influx of boundary cases in the last year this wasn’t just a technical disagreement but went to the heart of how courts determine general boundaries, and when extrinsic evidence can genuinely assist to interpret ambiguity, not cure poor drafting.


Under the general boundaries rule (s.60 Land Registration Act 2002), title plans show general, not exact, boundaries. If the wording of the transfer and the attached plan leave genuine uncertainty as to where the boundary lies, the court may look beyond the four corners of the document following Alan Wibberley Building Ltd v Insley.


Richard and Lizzie explore:


•How the court approaches “general boundaries” where transfer plans lack precision.

•The strict threshold for admitting extrinsic evidence and why it must be genuinely probative.

•Why post-dating conduct only carries weight if it is bilateral.

•The dangers of assuming planning permissions and approved drawings can later fix unclear title boundaries.

•What this means in practice for developers and local authorities


The High Court confirmed the County Court and held one party’s unilateral assumption about the boundary is irrelevant. The court’s role is to interpret the legal document, not to achieve what seems commercially sensible years later.


If you deal with development land, this is one to listen to before your next transaction.


Other cases mentioned include:

  • Alan Wibberley Building Ltd v Insley [1999]

  • Acco Properties Ltd v Severn [2011]

  • Maximus Networks Ltd v Secretary of State for Transport [2018]


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