The "GPDO Part 1 (All Classes) - LDC Appeal Decisions" document has been updated to include 1 additional appeal decision relating to householder permitted development legislation, for which the conclusions are as follows:

September 2026 - Code a01995 (appeal dismissed):

• This appeal decision provides an example of where a condition (on a previous planning permission) removes permitted development rights under a previous version of the GPDO but doesn’t refer to subsequent versions of the GPDO, and the Inspector concluded that the condition does remove permitted development rights under the current version of the GPDO.
  [Quote: “In order to benefit from any planning permission granted by Article 3 of the GPDO, the development must not be contrary to any condition on an existing planning permission: Article 3(4). Here, even though condition No. 06 relates to the Town and Country Planning (General Permitted Development) Order 1995, Section 17(2) of the Interpretation Act 1978 provides that the condition has a continuing effect in respect of the GPDO. For this reason and with no evidence to indicate that condition No. 06 has been removed or varied, I am content that this condition continues to have effect.”].
• This appeal decision provides an example of where a condition (on a previous planning permission) removes (some) permitted development rights by specifying particular works or Classes, and the Inspector concluded that the development is contrary to this condition.
  [Note: The condition requires that “[the vehicle] parking and garaging space and means of access thereto shall be kept available for such use at all times and no development ... shall be carried out on those areas of land or to preclude vehicular access thereto” (and refers to the GPDO 1995) but doesn’t refer to any particular Classes. The issue is whether this condition applies to the conversion of a garage into a “habitable room” (involving the replacement of the garage door with a window)].
  [Quote: “The appeal property was constructed with the benefit of planning permission granted on 5 March 2001 for the erection of 15 No. 4 bedroom, 23 No. 3 bedroom & 4 No. 2 bedroom houses together with associated garaging, parking, landscaping and access. The planning permission was subject to a condition (Condition No. 06) which states the following: “Vehicle parking and garaging arrangements shall be provided for each unit prior to its occupancy and thereafter the said parking and garaging space and means of access thereto shall be kept available for such use at all times and no development, whether permitted by the Town and Country Planning (General Permitted Development) Order 1995 or not shall be carried out on those areas of land or to preclude vehicular access thereto”. [...] Consequently, condition No. 06 restricts the use of the garage for vehicle parking/garaging and as such the conversion of the garage to a habitable room and removal of existing garage door and its replacement with a window, is development for which express planning permission is required, and that could only be granted on application to the local planning authority in the first instance.”].

Notes:

• To view the conclusions, summaries, and decision notices for any of the above appeals, please view the "GPDO Part 1 (All Classes) - LDC Appeal Decisions" document. As a member of the Planning Jungle website, you can view the decision notices for all of the appeals on the website for no extra cost.
• Any of the above conclusions marked with a "(*)" contradict other appeal decisions. The "Reference Section" within the above document indicates how many appeals have supported and contradicted each particular conclusion.